“Labour” with a “U”: Canadian vs. United States Labor Law

Episode Notes

Transcript

Matt Greer:

Hello, and welcome to the ABA Labor and Employment Law Podcast. I’m your host, Matt Greer. In my day job, I work for the Washington State Public Employment Relations Commission, where I spend most of my time serving as a public sector labor relations mediator, hearing examiner, arbitrator, and trainer, always as a neutral. Probably like you, my focus area is one small piece of the bigger labor and employment law universe. I enjoy broadening my horizons through this podcast and learning about what’s going on in the wide world of labor and employment law from experts in the field. On today’s episode, I’m honored to welcome Cody Yorke and Christopher Deehy to discuss the unique challenges and opportunities they face in their cross-border labor and employment law practice, particularly between Canada and the US. Christopher represents corporate employers and is a partner at the law firm of La Pointe, Rosenstein, Marshawn Melanson, based in Montreal.

Cody represents senior and executive level employees as a partner at the Law Firm of Withers and is based in New York City. We are very fortunate to have both Cody and Christopher on the podcast to share their experiences and wisdom. Be sure to check out their full bios in the show notes. Thank you so much for joining us, Christopher and Cody. Welcome to the show.

Christopher Deehy:

Thank you.

Cody Yorke:

Thanks, Matt.

Matt Greer:

It’s really great. I’m really looking forward to this conversation. I think myself as well as a lot of our listeners are probably really curious to hear about some of the distinctions between our neighboring countries here and as it relates to labor and employment law. So I really appreciate you coming to share that. I was thinking though, as we’re kind of starting off here, I wonder if it makes sense to address maybe what’s the elephant in the room a bit, which is the fast changing political dynamics in Canada, US relations these days. I think that everybody’s paying attention to the news at all. You see things going on. So for our listeners, we are recording this right as there are high level tariff negotiations going on. We don’t know what the result of that is to be honest at this moment, but it’s kind of in the news right now.

Things may be very different by the time you hear this episode, but that’s kind of the context for this initial start off question. We don’t want to delve too much into politics on this episode, but I think it’s kind of interesting and I’m sure most people are curious to hear your thoughts if any of that political stuff does have an impact on your practices when advising clients who might have interest in both countries. So I don’t know, Cody, do you have any initial thoughts on that?

Cody Yorke:

On a sort of day-to-day basis, there isn’t a huge immediate impact on my practice, but obviously politics will shape the legal structure, politics will shape the relationship between the countries and that will have an effect, but I think it’s at a larger level than sort of immediate effect. And I do think that the historical politics of the two countries has led us to what we have now where we have these two very different basic rules of engagement in employment law when there’s actually, in most other areas, a lot of similarity between the countries. This is one where there’s very different approaches between Canada and the US, and I think that comes from the historical political context.

Matt Greer:

Yeah, fascinating. So some ways the current dynamics are just a reflection of maybe some of the realities that historically have naturally come into play too. So yeah, Cristo, what do you think from your perspective? What are you seeing as a Canada based practitioner?

Christopher Deehy:

Well, I do labor and employment law as you know, but I’m in a firm that is very much a corporate and commercial firm, which historically does a lot of transactional work. So certainly over the last, I’d say roughly two years, there’s been a pretty marked decline in cross-border transactions, certainly from a Canadian perspective. So we’re seeing there’s been a sharp drop in US investment in Canada and resultingly fewer transactions. Other than that, as Cody said, it’s very much business as usual, although the atmosphere has certainly changed and there’s certainly less. Friendliness is perhaps not the right word from the Canadian perspective, but there’s certainly less security in the future as the current US administration has pursued what can only be. Has taken a dramatic, some might say radical turn in its attitude towards trade with Canada. And that is certainly having a marked effect up here where we have grown accustomed to having very cordial.

Not to say the relationship has always had bumps in the road, but other than the odd bump, certainly since World War II, the two countries have steadily moved closer towards greater cooperation militarily and very much in trade with the two trade agreements, one which you referred to earlier, which is currently being renegotiated. But there’s a marked change in the way the current American administration is dealing with its relations with Canada, and that is certainly having an impact within Canada and within Canadian politics.

Matt Greer:

Yeah. Thanks for sharing that perspective. I know as a US-based person here too, it’s kind of curious to hear we hear things from the news sources down here. It’s always interesting to hear what’s happening with our neighbors who are dealing with this from their perspective. So I appreciate you sharing that now as well as we move forward this conversation. So thanks for that. Well, I mean, I guess putting that aside, obviously we can talk about those issues that they come up along the way, but I mean, I think one of the impetus for this episode was to talk about some of the differences and also similarities between the Canadian and US based labor and employment law system. So I though maybe we’d start off by some of this, maybe talking about some of the differences and some of how the structural underpinnings of our laws maybe impacts things.

So I don’t know, Christopher, did you want to give us a overview of how Canada is set up?

Christopher Deehy:

Sure. So with respect to the similarities, Canada, like the US, is a federation with levels of government. Basically, we have 10 provinces in three territories and one federal government, and the Canadian Constitution distinguishes very clearly certain areas of jurisdiction in which all those governments are independent and sovereign, and it also dictates some shared jurisdictions. And so that’s one of the first things. And what flows from that, perhaps a notable difference between the two countries is that the criminal law is a federal jurisdiction, and so we have a single criminal code. However, labor and employment as well as contracts are of provincial jurisdiction, which means that each of the 10 provinces have their own distinct labor and employment law. Unlike in the US where you have the Wagner Act, I understand unionization falls under the purview of the US federal government. In Canada, each province has enacted its own Labor Code.

There is also a residual federal jurisdiction which governs employees of the federal government and employees employed in sectors that are regulated by the federal government, most famously banks, because banks are federal, also telecommunications and other such industries that travel across provincial borders. So there is a federal Labor Code, but the provinces play a much greater role in Canada with respect to unionization than I believe they do in the US. The other particularity is that of the 10 provinces and three territories, all except for Quebec follow the British tradition of common law. And so their civil law is based on a system which is similar to that you find in most of the US states with the exception, and each country has their own exception. I’m in the country in Canada, which is Quebec, which has the French civil code tradition, as does the state of Louisiana in the US.

I’ll stop

Matt Greer:

There, but that’s – There’s always the one exception, right? There’s always

Christopher Deehy:

One exception. And then just to add on to that, the province of Quebec, officially the federal government in Canada is bilingual. Some of the provinces are, some of them are not. There are pockets of French-speaking people throughout Canada, and so that also has an impact on some of the labor and employment law. One province, the one I’m in, Quebec, is the only one with a majority of French speakers, which on top of the distinct system of law and a population of nine million people makes it that it has its own particularities with respect to labor and employment, which is not to say that the other provinces do not have distinctions. They most certainly do, but Quebec is sort of the country within the country, certainly the somewhat different place than the other provinces are.

Matt Greer:

Yeah. We might learn a little about that always talk through some of the issues we’re going to be going into. But Cody, I was curious if you had anything to add on to that regarding the structure of the thing, anything that has impacted your practice and how things are set up differently in the two countries.

Cody Yorke:

Yeah, absolutely. And for context, I am a Canadian living in the United States

And I used to practice in Toronto before moving to New York. I like to tell people that the two countries, when we’re talking about employment law as opposed to labor law, come at it from exact opposite starting points. In the US, we have employment at will, and a lot of the principles of employment law here and the way the practice has evolved and what it means to be an employment lawyer comes from that. In Canada, there is reasonable notice of termination, and so it’s really a very different setup in the US. At-will employment means the employer and the employee can terminate employment at any time for any reason, as long as it’s not unlawful, whistleblower retaliation, discrimination, but otherwise there are some circumstances in which notice is required under warn if there’s a plant closing, but the default is that there isn’t any. And what flows from that is also an employer’s broad rights to change the terms of employment.

And that means that we don’t really have in the US a very strong concept of constructive discharge or constructive dismissal. On the flip side, in Canada, employees generally have a right to some notice of termination, some advance notice, some amount of severance. So in the provinces, each province has a statute that sets out a minimum statutory notice and severance that employees are entitled to receive.

Employers and employees cannot contract out of that minimum notice. Employers cannot get a release in exchange for providing it, and they can face additional damages if they don’t pay the proper notice and severance under the statutory minimum. Then on top of that, Chris had mentioned it’s a common law country in most of the country, and there is what is called common law reasonable notice, which asks what would the imaginary person in the same position, how long would they need to find new comparable employment? And that’s where a lot of the practice as an attorney representing employees, that’s a lot of what you’re doing. You’re arguing over how long the reasonable notice is, and that is not the case in the US because you don’t have a legal claim for wrongful dismissal. It’s a very different practice day to day because of that, and it’s also a big learning experience for executives, for employees, and Chris probably has the same experience with his clients when they’re moving from one country to the other and entering a new system.

In both directions, I think it’s a little bit of a shock to people how different it is.

Matt Greer:

Yeah, I was thinking that it would be a little bit of a culture shock if you had a company or an executive or an employee who’s more familiar with one of those cultures and puts their foot in the other one and be like, “Wow, that’s pretty shocking,” and also fascinating. Yeah, the whole notice period and severance amounts are actually set out in Law. Is that what you’re saying, Cody? I think that’d be interesting. I think the notice provision maybe makes some sense in the US with the Warren Act and other kind of layoff provisions, but it’s interesting to hear that there’s actual severance payments that are laid out too. I think that would be surprising to most of our folks, certainly to me.

Christopher, I don’t know. I mean, I imagine that you probably do represent some of your corporate clients who maybe have more of a foot, more in the US and they’re coming up maybe to Canada. I guess, do you have any tips for those folks who are looking at that cross-border business practice and what they could be thinking about? I guess I’m curious if you have any kind of thoughts for. And vice versa, if you have your Canadian clients who are looking to go to the US, I’m just curious, what kind of things do you tell them to prepare them for that perhaps big change?

Christopher Deehy:

Well, being as I am in the province of Quebec, the first thing I point out to them is that Quebec seeks to function in French. And so if you are going to be setting up a business in Quebec, you are going to need to be equipped to manage, converse, and carry on business in French, also in English, but that’s one particular distinction. With respect to labor law, beyond the fact that we spell labor with a U, we also. And surprisingly, we adopted the unionization model, the industrial relations model on which Canadian unionization is founded is not the one that you find on the European continent, but it is modeled on the US Wagner Act and the US model where it is an establishment within a company where unionization occurs. And if there is a majority of members who wish to be unionized, they become certified.

All of the Canadian provinces have labor boards, and those labor boards will then certify the union. And then at that point, the employer is obliged to engage with the union in good faith bargaining with a view to concluding a collective bargaining agreement. So in that regard, it’s very similar to the US model with the same types of protections that you would also find for anti-union activity and those sorts of things. But that is often where the similarities end. One of the distinctions, and it varies from province to province, but is in the way certification is actually granted. Some provinces allow voluntary recognition, others don’t. Some require that there be a vote like you have in the US. Others operate on the basis of card check only, which means that there may not be a vote.

And so there’s that. The other particularities is many provinces have now enacted limitations on the right that an employer has to hire replacement workers during work stoppage, be it a lockout or a strike. And from a US perspective, and I know this from having had over the years, a great many conversations with Americans who are confronted with a unionization drive in Quebec, the legislation here, my clients, my American clients would say severely, I’m not sure, but clearly materially restricts the capacity that an employer has to intervene directly and campaign in a unionization drive when one is going on or when a vote is going to be held. When you compare things to the way I understand things operate in the US where there seems to be a good deal of pretty active campaigning. So those are some, but I would say the most important differences between unionization.

So I guess it would be sort of a differing application in Canada of what is essentially the US model, industrial relations model.

Matt Greer:

Yeah, it’s fascinating. And it does sound like which province you’re in is really going to impact that in a different way than which state you’re in the US in the private sector anyway. So yeah, it’s fascinating. I’m curious though, I am a collective bargaining labor relations person in my background. I’m curious, is the scope of bargaining really different between the provinces? Is what can be bargained at the bargaining table kind of differ quite a bit between provinces or is that kind of standardized a little bit?

Christopher Deehy:

It’s pretty standard, at least as far as I know. There may be some nuances that I do not grasp, but certainly in Quebec, it’s pretty much anything that would fall in the broad sense, it could constitute a work condition that’s not otherwise illegal. So it’s pretty broad. And the line between who can be unionized, who’s in scope and who is not is also very much modeled on the Wagner Act. So normally most provinces at first level management upwards, so I would say normally what we called when I was younger, a foreman upwards are excluded from the possibility to be unionized. Okay. Yeah, that’s pretty much constant in Canada.

Matt Greer:

Yeah. Okay. Fascinating. And I guess maybe transitioning back to more of the employment law world, Cody, your kind of area, I know when we had an initial conversation that there was an indication that maybe the use of restricted covenants in employment was one of the key pieces that you look at in your practice when you’re representing your clients. And Christopher, I’m sure you see it as well, but curious, do you want to give us an overview of what the nature of restrictive covenants are generally and what the differences are between the two countries?

Cody Yorke:

Sure. So in my work, because my clients are executives and senior level employees, almost always they have some form of restrictive covenants, unless of course they’re in California or there are increasing number of states that are enacting non-compete bans and other legislation that limits the use of non-competes and restrictive covenants. And that is really one of the topics that comes into play a lot is the choice of law in an employment contract, because that will govern the interpretation of the restrictive covenants. And some states have enacted laws to limit the use of other states’ law for employment contracts for employees who are working in their state. And it’s been, I would say, a bit of a cat and mouse game over the last decade, and it’s continuing to be a constantly changing area of law in the US. But restrictive covenants, unless there is a piece of legislation that limits them, they are enforceable if they are reasonable and they are reasonably required to protect an employer’s interest.

And the prevalence of non-competes in US is kind of staggering the use with not just high level employees, but with lower level, entry level employees having non-competes, having non-solicits, having onerous post-employment restrictions that a lot of the time they may not even understand what they’ve agreed to when they sign it. That, in my experience, and which is admittedly a little out of date from when I used to practice in Toronto, but restrictive covenants were not nearly as commonly used and were much harder to enforce. I think that that flows from the same basic difference in the way employment law is approached in the countries where in Canada, there is this fundamental concept of employee rights, that an employee, an individual has a right to work, and that same concept does not underpin much of the US employment laws.

Matt Greer:

Yeah, that’s really interesting. Christopher, do you see the use of restrictive covenants at all or is there interest in your clients to do that? I don’t know, in terms of the cross-border dynamics, do you have conversations with your clients about how they are or not used variously?

Christopher Deehy:

Definitely. So to just sort of carry forward from what Cody was sort of saying, you definitely see, certainly in Quebec and Ontario now, these clauses will only be enforceable if the employer can demonstrate that it has a real need for the clause. And by here, I’m speaking more with respect to non-competition clauses. Courts take a much more lenient view of non-solicitation clauses, which they are much more less hesitant to enforce because they don’t normally impact on the right to work. And the same thing with non-disclosure agreements. But when it comes to non-competition clauses, I forget what year, but about five or six years ago, the government of Ontario enacted legislation which basically prohibited non-competition clauses for employees save and except for true senior managers, or like we often say, the C-suite executives, CEO, executive vice president, CFO, et cetera. Quebec is, so as far as I know, it is the only Canadian province that has done that, although recently the federal jurisdiction has enacted similar legislation under the Canada Labor Code.

So yes, we see them and for senior employees, these clauses are enforceable provided that they are tailored to the employer’s requirements and are reasonable with respect to scope of activity, time, and geographic area.

Cody Yorke:

I’ll just add with many of the clients that I work with, there is another sort of concept that’s frequently used, which is a forfeiture for competition. So executives will have a large portion of their compensation deferred in some way and subject to forfeiture if they compete. And what that means is that the court doesn’t get into. In most states, I will caveat by saying there’s some differences in state law here, but in many states, the court will not get into an analysis of whether the restriction is reasonable because the former employee has the choice between competing and forfeiting the compensation or keeping the compensation by not competing. And so that is where a lot of non-competes lie in the US.

Matt Greer:

Okay. Yeah. Very interesting. Yeah. The nuances are just not apparent on the face of things, but you deep down it’s pretty interesting how those different approaches are. I think I remember hearing about that in some places that even in the US that even fast food workers would be asked to engage in a non-compete agreement to not go at McDonald’s to go over to Burger King or something across the street. And that was interesting. I was just hearing a little bit about that and it sounds like that would be a very different approach versus in the US versus Canada with those types of things. So thanks for sharing that. Yeah.

Yeah. I guess maybe this might be a good time. We’re a little over halfway through our time. Let’s go ahead and take a quick break. I want to give the ABA Labor and Employment Law Section an opportunity to tell us about some of the upcoming events that are happening. So we’ll take a quick break and when we come back, I’ll ask you both if there’s any other things that should be on people’s radars if they’re thinking about the Canadian and American difference and approaches on any other interesting So be right back. All right. And we’re back. So it’s really interesting to hear about the differences in the labor law, the collective bargaining world and some of the employment law worlds, the non-competes and that approaches. Are there other big areas that you think of as being different between the US and Canadian approaches or even similar that might be surprising?

Just curious if you had any other big topics that should be on people’s radars as they’re thinking about the cross-border dynamics here.

Christopher Deehy:

Well, two that spring to mind for me that we haven’t touched upon yet is the issue of successor liability with respect to employment matters in the context of transactions. Most Canadian provinces, but to a varying degree, will provide for some type of successor liability for a successor employer, even in circumstances where the employer is buying assets of a target company as opposed to buying shares. So that’s something that is often, as far as I know, built into pretty much all of the Labor Standards legislation in the country. And just power to add to that, because Quebec’s common law is codified, there is a provision in the Quebec Civil Code which applies to transactions for all employees. And so it means that there’s even under Quebec common law, if an employer acquires a business or the assets of a business, but continues to operate the business is a going concern, there will be a certain successor liability.

And basically just to summarize it, when the employer acquires the assets, the employer essentially also acquires the employees and their existing employment contracts. So that’s something to bear in mind. Another notable difference is the view that the Canadian courts and the Canadian governments have taken with respect to privacy and especially with respect to things such as substance testing in the workplace. Generally speaking, the Supreme Court of Canada has rendered several judgments on this issue over the years. Generally speaking, employers right to engage in substance testing in the workplace is limited strictly to safety sensitive positions and often only in circumstances where the employer can demonstrate that there is a definitive and clear problem. And even then it’s very difficult to engage in random substance testing with the exception of such obvious industries like if you’re an airline pilot or if you are directly involved in transportation.

But the Supreme Court has taken a very restrictive view of that.

Matt Greer:

Yeah, fascinating. Cody, I’m curious if you had any thoughts on those two pieces or if there were any other things that were on your radar people should be aware of?

Cody Yorke:

I think that one of the areas where there is a lot of similarity I think between the two countries is when you look at the issue of accommodation for people with disabilities, there’s a very similar approach between the two and a concept of reasonable accommodation and the interactive process to figure out what accommodation is required. Those are very similar. But when you look at discrimination cases and harassment cases and you look at the damages amounts, there’s a very big difference between the Canada and the US. In Canada, we don’t have the same or they don’t have these sort of multimillion dollar settlements and judgments in employment law cases the way that we do in the US where a single case can be very, very valuable. In Canada, everybody has basic level rights, but nobody is getting some exceptional award. And in the US it’s sort of the opposite.

Matt Greer:

Yeah, very interesting.

Cody Yorke:

And I think the other piece that comes into play is the importance of contracts and who the contract is important for and in what way. In Canada, often an employment contract is limiting the employees’ rights, is limiting the entitlement to common law reasonable notice. In the US, a contract will be the source of a severance entitlement. And so they’re sort of doing different jobs on the same topic. And so that’s a different approach, but the result is the same that the employment contract is very, very important.

Matt Greer:

Yeah. Very interesting. I don’t know Christopher if you had any follow up thought on those pieces, but I also wanted to, while we still have a few minutes, Christopher, if you wouldn’t mind, I’m really curious about the practical differences between the civil code kind of approach and the common law approach. How does that actually impact your practice in Quebec versus if you were in a different province? I’m just kind of curious how that actually plays out. I kind of know generally about those differences, but just in terms of the practicalities of that, I’m just curious to hear a little bit more about that if you’re willing to share.

Christopher Deehy:

Sure. So the civil code is based off of, roughly speaking, is an offshoot or a descendant of Justinian law and would be similar to civil codes that you would find in Europe, which are also is Roman law that was sort of discovered in the 13th century and then it evolved. But the idea about it is that it works very much like a statute. It just lists, basically it codifies and states clearly how things work. Whereas in the common law, that’s evolved over time through jurisprudence. And so judge made law as opposed to government made law, except it’s a statute that doesn’t change all that often. What it does, it sets out, for example, I used to know how many, so I’m saying this publicly, but don’t quote me, I believe it’s 14 nominate contracts and it says this is a contract of employment and this is how it works.

And the same thing for a contract of sale or a loan. And so what that means is when you’re drafting a contract, you don’t have to incorporate in civil law or in a civil law jurisdiction some of the things you might otherwise feel you have to incorporate in a common law jurisdiction because here you can rely on the civil code because the articles of the civil code are incorporated by the contracts. And so among other things, it makes for much shorter contracts, at least in theory. Although we also, sometimes lawyers being lawyers want to state the obvious anyway, so it could sometimes be as long, but it’s very Cartesian. So someone asks me what are the requirements for a valid non-competition clause? Well, there’s a chapter on employment contracts and I forget if it’s 2094 or 2095, but it’s there and it states exactly in shockingly or surprisingly plain language what’s required.

So that I think would be the first thing. And what that means is that the case law is important and case law is invoked when we’re before the courts, but the concept of precedent does not apply in Quebec the way it does or under Quebec civil law is the way it apparently does in common law provinces where the courts are sort of creating law. Whereas here we’re starting from law that’s already there and only really interpreting it if it’s not clear.

Matt Greer:

Wow. A little history lesson there. Just Indian codes and that’s fascinating.

Christopher Deehy:

And just the complete history code is that, of course, Quebec is what was initially New France and in New France they brought what they called the custom of Paris because at the time basically they incorporated French law. And when Quebec transferred over in what we call the conquest, when it ceased to be a French colony and became a British one, the British being the pragmatic folk that they can be at times decided that it was much simpler to just keep that legal system in place rather than try to change it. So they did. And that’s what we now have today.

Matt Greer:

Yeah. Fascinating. So it sounds like for folks who are in the US who are thinking about a cross-border practice, you have to be extra careful if you’re going over into Quebec as opposed to perhaps Ontario, as Cody has experience in. Yeah. All right. Well, we are kind of coming close to the end of our time here. I wanted to give you both a chance to, if there’s anything else that we didn’t cover that you wanted to kind of touch base on, but also I’m really curious if you had any kind of tips for folks who are maybe having to deal with cross-border issues generally as maybe a tangent in some of the practices, if you have any kind of just kind of parting tips for them. And then I also want to give you an opportunity, I think one of the inspirations for this episode is some of the cross-border collaborations that have occurred, I think between the American Bar Association and the Canadian Bar Association.

I understand there’s some opportunities there. I’m curious if either of you have any kind of experiences with those cross-border collaborations, any value that you may have found from having those conversations. I know just from this episode, it seems like there’s a lot of value in chatting through some of these issues, but just wanted to get your perspectives on that. Any tips and any words of wisdom regarding looking for cross-border conversations with folks?

Cody Yorke:

I mean, I think two tips from my perspective. One, get tax involved. If you have cross-border employment, you have cross-border tax issues and you need to be thoughtful about it. And two, you need to have counsel in the jurisdictions that you’re dealing with and you need to have counsel who are not just familiar with local law, but who practice internationally. And that leads into your second question about the value of these sort of collaborative conversations. I’m a co-chair of the ABA’s Labor and Employment Law Section International Committee, and I’m also on the Outreach to International Lawyers Committee because I think it is so valuable to have conversations with lawyers in other jurisdictions and to hear conversations like this one, conversations like we have at our conferences where we talk about different approaches to law in different countries and you’re able to get these different views, which I think you can bring into your practice and think more creatively when you encounter new situations.

And you also get to make great connections like with you two when you have an issue come up down the road and you think, oh, I need counsel in Quebec. Now I know Chris.

Matt Greer:

Great. Yeah. Christopher, what about you?

Christopher Deehy:

Well, with respect certainly to the collaboration piece, I’m a former chair of the Canadian Bar Association’s National Labor and Employment Section. And we have always. Of course, there was pre – COVID and post COVID and somehow things lost somewhere in between, but we’ve historically always been interested in trying to get a US perspective included. We do an annual conference with Administrative Law. We work with them. We’ve often tried to get American speakers up. I mean, Canadians, our economies are amongst the most integrated in the world and a lot of what goes on in the United States has an impact. I’m not just mentioning politically, but I mean socially, often a lot of things that we see coming up through labor and employment in the United States trickles over and ultimately has an impact in Canada. So we’re always interested in having American lawyers coming up and participating either as speakers or in podcasts.

I believe two years ago we did one, the Canadian Bar Association, the ABA with respect to what we touched on today, which was restrictive covenants because there was some very interesting differences. So yes, we’ve always seen it as being extremely positive when we can get these kinds of discussions happening between our two countries.

Matt Greer:

Yeah. No great thoughts. I was involved in the Association of Labor Relations Agencies, which is an organization that is labor agencies in the US and Canada. We get together once a year for a conference and it’s really fascinating to hear about my colleagues who are working in Canada, the different differences in our laws that we administer. I also will add into that encouragement for folks to be thinking about that, even if it doesn’t necessarily directly impact your practice. I think it really does broaden horizons a bit to thinking about how different jurisdictions handle different issues. It’s interesting at the very least, but also maybe kind of makes you think differently about the work that you do in a broader way. So appreciate you both sharing those tips there. Well, we are pretty much at the end of our time. So I wanted to say Christopher and Cody, thank you so much for taking the time to join us on the podcast.

I definitely learned a lot. I thought that was fascinating. I’m sure our listeners were very, very fascinated by that as well and learned a lot. I want to thank our listeners as well for taking the time to listen in on this podcast and be sure to give us a follow on your favorite podcast player and then give us a like and make sure you let your colleagues know about us as well. So spread the word. All right. Thank you very much and I’ll talk to you next time.

Christopher Deehy:

Thank you.

Cody Yorke:

Thank you, Matt.

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