IN THE MATTER OF THE HOSPITAL LABOUR DISPUTES ARBITRATION ACT

AND IN THE MATTER OF AN INTEREST ARBITRATION FOR A RENEWAL

COLLECTIVE AGREEMENT

B E T W E E N :

GROVES MEMORIAL COMMUNITY HOSPITAL

(“the employer”)

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ONTARIO PUBLIC SERVICE EMPLOYEES’ UNION

(“the union”)

BEFORE: John McNamee, Chair Larry Robbins, Union Nominee Brian O’Byrne, Employer Nominee APPEARANCES: For the Employer: Dan McPherson (Bass Associates) Yakov Sluchenkov ((Chief Human Resources Officer) Sarah Shepperd (Human Resources Business Partner) Kaush Patel (Manager of Diagnostic Imaging Brenda Holiday (Labratory Manager)

For the Union: Manzur Malik (Spokesperson, Research Officer)) Marc Casey (Negotiator) Cathy Beardmore (Bargaining Committee Member) Terrie Davenport (Bargaining Committee Member) Nancy Rumph (Bargaining Committee Member) A hearing took place at Guelph, Ontario, on March 5, 2020, following which the parties filed written submissions. The Executive Committee met, via Zoom, on June 2, 2020.

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A W A R D

The parties were unable to resolve all of the issues with respect to the contents of a first

collective agreement, and therefore referred to this board the outstanding disputes. There was no

disagreement as to our jurisdiction to decide these issues.

The parties did not agree on a term for the new agreement; however neither of them suggested

that the Hospital Labour Disputes Arbitration Act did not apply, in the absence of an agreement.

The union provided notice to bargain on October 2, 2018.

By way of background, this employer is a public hospital located in Fergus, Ontario. It is part of

the Wellington Health Care Alliance, which also includes North Wellington Health Care (which

has facilities in Mount Forest, Ontario (Louise Marshall Hospital) and in Palmerston (Palmerston

and District Hospital). Each hospital provides a comprehensive range of in-patient and out-

patient services, including 24/7 emergency and obstetrical care.

The union, the Ontario Public Service Employees’ Union, is one of the largest unions in Ontario,

and represents a wide range of employees, primarily in the public sector. In the hospital sector,

the union bargains centrally with the Ontario Hospital Association (which represents (in

bargaining with OPSEU) some 80 different hospitals throughout Ontario, in respect of central

issues affecting 24,000 employees.

At this facility, the union represents a bargaining unit that currently includes approximately 35

employees (11 full time and 24 part time (including casual)). These employees work as Lab

Assistants, Medical Lab Technologists, Medical Radiation Technologists and Ultrasound

Technologists. The comparable bargaining units at Louise Marshall Hospital and Palmerston

and District Hospital are non-union.

The parties met and bargained on June 17, 18 & 20, 2019, and met in conciliation on July 31,

2019. The No Board Report issued on August 20, 2019.

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THE CRITERIA

The Hospital Labour Disputes Arbitration Act mandates an interest board of arbitration to

consider any factor which it considers relevant, but requires it to include the following five

criteria:

a) The employer’s ability to pay in light of its fiscal situation;

b) The extent to which services may have to be reduced, in light of the decision or

award, if current funding and taxation levels are not increased;

c) The economic situation in Ontario and in the municipality where the hospital is

located;

d) A comparison, as between the employees and other comparable employees in the

public and private sectors, of the terms and conditions of employment, and the nature

of the work performed; and

e) The employer’s ability to attract and retain qualified employees;

The parties also argued that the replication principle should apply, and that we should consider

comparability to other employers and bargaining units, as well as total compensation and

demonstrated need. To that end, they provided the Board with a variety of economic data,

including summaries, and in some cases the text, of memoranda of agreement and arbitration

awards from within, and without, the hospital sector. We have considered all of the statutory

criteria, the economic data, the precedents, and the arguments placed before us.

The employer did not argue that it had an inability to pay. The union did not submit that the

employer had had difficulty in attracting and retaining qualified employees.

However, the Board is also required to consider the terms of the Protecting a Sustainable Public

Sector For Future Generations Act, 2019 (“Bill 124”) which received royal assent on November

7, 2019, and it is this legislation which forms the focus of the real dispute between the parties.

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POSITIONS OF THE PARTIES

A. Application of Bill 124

Although it accepts that Bill 124 applies, the union urges us to disregard the provisions of that

legislation, and to issue our award as we would normally do if Bill 124 was not in place. It

submits that the principles of comparability and replication should take precedence and that we

should award the central terms and conditions of employment which apply to all, or almost all, of

its hospital bargaining units. It says that its members at this employer should receive the same

central terms and conditions of employment as apply to its members at hospitals across the

province. In that regard, it notes that this employer pays less than the central agreement in

respect of:

a) Stand-by pay;

b) Shift and weekend premiums;

c) Meal allowances;

d) Change of Schedule;

e) Percentage in lieu of benefits; and

f) Wages (where, as of April 1, 2020, some of the differences exceed $5.00 per

hour).

(NB It should be noted that not all of the OPSEU bargaining units receive the central

standards even on central issues such as wages, and that there are some few monetary provisions

of the existing terms of employment in this bargaining unit which exceed central, and which the

union seeks to retain.)

The union also submits that the integrity of the central bargaining arrangement is diluted if

hospitals are permitted to deviate from the central standards. Arbitrators, it said, are not rubber

stamps for government policy, and should not ignore the underlying purposes and principles of

the interest arbitration process, and of social justice, in making an award which flies in the face

of those long standing themes.

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Finally, the union also asserts that Bill 124 is unconstitutional, although in light of s. 28(2)

thereof, it does not ask us to make a finding it that regard.

The employer did not take a position on many of the union’s arguments, but submitted that Bill

124 was not a guideline (unlike many of the union’s examples) but was mandatory legislation

which required this Board to comply. It further noted that its funding had increased by only one

percent and that the union’s proposals would cost substantially higher sums.

Decision on the application of Bill 124

Despite the union’s arguments, we are of the view that we must apply Bill 124. In so saying, we

echo the words of Arbitrator Gedalof in the recent decision in Mon Sheong Home for the Aged v

Ontario Nurses' Association, 2020 CanLII 8770 (ON LA). The legal issues and arguments

before Arbitrator Gedalof were substantially identical to the positions taken before us with

respect to this issue, and he held as follows:

13. Having carefully considered the materials and arguments put forward by the parties, we

must conclude that Bill 124 applies to the Mon Sheong homes. !

16. Neither can we simply ignore the strictures of Bill 124 in this case. As an administrative

body, this board of arbitration is a creature of statute, carrying out the function assigned to us by

the legislature. In this regard, the circumstances in which we find ourselves are not the same as

those of the Albertyn board in Casey House, where Bill 124 was not yet law, and where both the

future and potentially retroactive application of the Bill was not yet fixed. Neither are they the

same as the circumstances of the Shime board in McMaster, where he found that it would be

inappropriate to permit government funding decisions alone to dictate the outcome of an interest

arbitration where all of the relevant and appropriate considerations together supported a different

result. In the case of Bill 124, we simply do not have such latitude; sections 10 and 11 dictate

that, (subject to the exceptions set out in s.10(2) of the Act, which are not applicable in this case),

no arbitration award may provide for an increase in salary or existing compensation entitlements

of more than one percent. ONA has put forward several arguments with respect to the disruptive

impact of this limit on long-established bargaining patterns. But these grounds are not a basis

upon which Bill 124 permits this Board to circumvent the wage restraint provisions. These and

other arguments may underly ONA’s constitutional challenge to the Bill, but that is an issue the

legislature has left to the courts.

In the result, with respect to this issue, we believe that we have no choice but to apply the fiscal

limitations set out in Bill124, notwithstanding that we would most likely have reached a different

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result if the legislation did not apply. Accordingly, this collective agreement will constitute the

first two years of the “Moderation Period” described in the Bill.

However, we, (as did Arbitrator Gedalof) remain seized with this matter in accordance with

subsection 9(2) of the HLDAA, including with respect to a re-opener on compensation proposals

in the event that OPSEU is successful in having Bill 124 declared unconstitutional by a court of

competent jurisdiction; if the Bill is otherwise amended or repealed; the responsible Minister

grants an exemption; or if, for any other reason, the limits set out in ss. 10 and 11 no longer

apply.

B. The application of ss. 10(1), 11(1), 11(2) and 11(3) of Bill 124

Sections 10(1), 11(1) and 11(3) of the Bill read as follows:

10 (1) No collective agreement or arbitration award may provide for an increase in a salary rate

applicable to a position or class of positions during the applicable moderation period that is

greater than one per cent for each 12-month period of the moderation period, but they may

provide for increases that are lower.

11 (1) During the applicable moderation period, no collective agreement or arbitration award may

provide for any incremental increases to existing compensation entitlements or for new

compensation entitlements that in total equal more than one per cent on average for all

employees covered by the collective agreement for each 12-month period of the moderation

period.

(2) For greater certainty, an increase in a salary rate under subsection 10(1) is an increase to

compensation entitlements for the purposes of subsection (1).

(3) If the employer’s cost of providing a benefit as it existed on the day before the beginning of the

moderation period increases during the moderation period, the increase in the employer’s cost

does not constitute an increase in compensation entitlements for the purposes of subsection (1).

As is clear, there is a difference between ss. 10(1) and 11(1) of the Bill. Section 10(1) prohibits

increases in “salary rate” in excess of one percent, while s. 11(1) provides some latitude in

permitting incremental increases in existing compensation entitlements or new compensation

entitlements up to one percent of total bargaining unit compensation (less any amount allocated

to the salary rate).

The term “salary rate” is defined in s. 2(b) of the Bill to be:

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“salary rate” means a base rate of pay, whether expressed as a single rate of pay, including a

rate of pay expressed on an hourly, weekly, bi-weekly, monthly, annual or some other periodic

basis, or a range of rates of pay, or, if no such rate or range exists, any fixed or ascertainable

amount of base pay.

The employer has provided costing information in respect of its just completed fiscal year as

follows:

Total Compensation for the bargaining unit

(including wages, wage related items and non-wage

related items*): $2,285,506.00

Straight time wages $1,470,633.70

Wage related items (includes Overtime, Callback,

Group Life Insurance, Long Term Disability, Pension,

Part Time in Lieu, Vacation Pay, Paid Holiday Premium,

Telephone Consultations and Pregnancy/Parental Leave) $ 678,449.26

Non-wage related items (includes Shift Premiums, Weekend

Premium & Standby Pay, Extended Healthcare, Semi-

Private, Dental & Responsibility Allowance) $ 136,422.93

* the characterization of these items as wage related and non-wage related is the

employer’s, not the Board’s. The union did not disagree with the numbers provided by

the employer.

The employer has also provided some costing as to the union’s proposals but has not costed

proposals in respect of Meal Allowance, Transportation Allowance, Scheduling language, and

Call back for lack of sufficient data, but submits that there is a cost component to those issues.

The narrow issue between the parties in respect of these figures comes down to the issue as to

whether, as the employer contends, the “wage related items” should be considered in calculating

any amount available for monetary improvements under s. 11(1) of the Bill, or whether those

wage related items fall within the exception set out in s. 11(3).

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The difference in calculation comes to this: Employer – Total compensation $2,285,506.00 less Straight time wages $1,470,633.70 less Wage Related Items $ 678,449.26 equals $ 136,423.04

multiplied by 1% $ 1,364.23

The union submitted that the employer is wrong in including the Wage Related Items, and said

that the proper calculation is:

Union – Total compensation $2,285,506.00 less Straight time wages $1,470,633.70 equals $ 814,872.30

multiplied by 1% $ 8,148.72

Thus, there is a difference of approximately $6,800.00/year between the two parties as to the

amount available for non-wage monetary improvements. Neither side was able to point to any

decision which explicitly dealt with this issue.

The union submitted that section 10(1) of the Bill limits increases in salary rate to 1%, and that

“salary rate” as defined in s. 2(b) means, in the case of hourly rate employees, an increase in the

base hourly rate only. It therefore submitted that any consequence of an increase in the base

hourly rate (aside from an increase in straight time wages) is exempted from the calculation to be

made under s. 11(1) by virtue of s. 11(3).

The employer took the view that the purpose of s. 11(3) was to account for changes that might

occur with a benefit prior to the moderation period, if there were no changes in compensation. It

posited that the purpose of s. 11(3) was to account for matters such as increased usage of benefits

or sick leave; increases in the premium charged for insured benefits; changes in the number of

full-time versus part-time employees, or an increase in frequency of usage for a premium (e.g.

number of weekend hours worked). In its view, s. 11(3) was not intended to provide an increase

in excess of 1% total compensation, and asserts that (if increases in the “wage related items” are

not taken into account), the actual increase annually is equal to 1.3%.

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Decision on the application of ss. 2(b), 10(1) and 11 of the Bill

We do not doubt that the interpretations put forward by both sides are arguable, but we find that

the union’s view is preferable. There is nothing in s. 11(3) which limits the application of that

sub-section to the kind of cost increases suggested by the employer, and we do not agree with

interpreting the sub-section so narrowly unless there is clear language, which there is not, which

requires us to do so.

Our analysis of the relevant sections of the Bill is as follows:

a) pursuant to s. 10(1), we may not increase the salary rate for employees in the

bargaining unit by anything in excess of 1% in a moderation year. The salary rate in this

context; and pursuant to s. 2(b), denotes the hourly rate:

b) pursuant to s. 11(1), we may not provide, in any moderation year, for “any

incremental increases to existing compensation entitlements or for new compensation

entitlements that in total equal more than one per cent on average” for the bargaining

unit. S. 11(2) requires us to include the amount of the hourly rate increase in the

compensation entitlements referred to in s; 11(1); and

c) in terms of the calculation of any increase in compensation entitlements pursuant

to s. 11(1), s. 11(3) sets out that an increase in employer cost in providing a benefit as it

existed on the day before the moderation period began is not to be included in calculating

any increase in compensation entitlements referred to in s. 11(1). We have given the

widest possible meaning to the word “benefit” (which is not defined in Bill 124) as

employed in s. 11(3) in that we assume that the legislature intended to include any

monetary entitlement payable by the employer to employees, including direct payments

of money and indirect payments made pursuant to an insurance or other policy referred to

in the collective agreement.

However, if the legislature had intended a limit on employer cost it could have done so, and it

could have specified that the s. 11(1) limit included all consequences of the increase in the

hourly rate. Instead it did the opposite, and provided subsection 11(3) which exempts the cost of

providing benefits (as they existed on the day before the moderation period commences) from

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consideration in the calculation to be made pursuant to s. 11(1). Thus, for example, if there is an

increase in the cost of providing Pregnancy/Parental Leave during the moderation period (and

assuming no change in the collective agreement provision dealing with that issue) s. 11(3) not

only exempts from s. 11(1) the cost of an increase in the number of such leaves taken during the

moderation period, but is also broad enough to exempt an increase in cost attributable to an

increase in the salary rate.

If the legislature intended a different result it could have indicated that it differentiated between

different sources of employer cost increases. Since it did not, we see no reason for us to impose

a distinction that it did not.

As to the employer’s argument that, if the “wage related items” are not included in the 1%

increase in the hourly rate, the increase in total compensation described in s. 11(1) will exceed

1%, it is our view that the legislature, in s. 11(3), specifically contemplated that total cost to the

employer could increase beyond 1% without impacting total compensation under s. 11(1). Our

view, in that respect, is reinforced by the use of the term “wage rate” in both ss. 10(1) and 11(2)

of the Bill, and the definition of “wage rate” (i.e. hourly rate) as the only limitation referred to in

s. 10(1).

Accordingly, it is our view that the amount of $8,148.72 is available to us in each year for

increased, non-wage benefits.

ORDER

In light of all of the circumstances and submissions, the Board makes the following award. The

parties are therefore directed to enter into a collective agreement which consists of:

1. (a) Retroactive to October 2, 2018, increase all hourly rates by 1%; and (b) Retroactive to October 2, 2019, increase all hourly rates by 1%: 2. Term – In accordance with the Hospital Labour Disputes Arbitration Act,

October 2, 2018 to October 1. 2020:

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3. Retroactive to October 2, 2018: a) Increase percentage in lieu (Article 21.05) by one percent to 9.5%; b) Increase Afternoon/Evening shift premium (Article 18.04) by ten cents to

$1.65 per hour; c) Increase Night shift premium (Article 18.04) by fifteen cents to $1.70 per

hour; d) Increase Weekend premium (Article 18.05) by fifteen cents to $2.15 per

hour; 4. Retroactive to October 2, 2019; a) Increase stand by pay (Article 18.01) by thirty cents to $3.30 per hour; b) Increase percent in lieu (Article 21.05) by 0.5% to 10%; c) Increase Afternoon/Evening shift premium (Article 18.04) by ten cents to

$1.75 per hour; d) Increase Night shift premium (Article 18.04) by twenty-five cents to $1.95

per hour; e) Increase Weekend premium (Article 18.05) by fifteen cents to $2.30 per

hour;

5. The retroactivity amounts referred to in paragraph 1, 3 and 4 above are to be paid

by separate check/deposit to current employees within three pay periods of the

date of this award. Persons who worked in the period from October 2, 2018,

onwards, but who are no longer employed, will also be entitled to payment of

retroactivity. The employer is directed to send a letter within three pay periods of

the date of this award to the last known address of each such ex-employee,

advising them of their right to retroactivity. Ex-employees will have 30 calendar

days from the date of mailing to claim payment. Ex-employees who fail to claim

their payments within the 30 day period shall be deemed to forfeit any claim

thereto;

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6. With respect to the language of the agreement, and subject, where applicable, to the monetary amounts set out in paragraphs 1, 3, and 4 on pages 10 and 11 hereof, we hereby award;

a) the union’s language regarding seniority accumulation and transfer

of seniority (Article 11.03), as set out on pp. 31 and 32 of its brief; b) status quo, as proposed by the employer in the alternative, with

respect to bereavement leave (Article 15.03) We remit to the parties the task of setting out this provision in language appropriate to the collective agreement;

c) the union’s language with respect to sick leave and long term

disability (Article 16.03) as set out on page 39 of its brief. We understand this provision to represent the status quo;

d) the union’s language regarding shift scheduling (Articles

17.12 and 17.13) as set out on pages 40 and 44 of its brief, except that the employer’s definition of a weekend (Article 17.13(b)) as set out on Tab 9, page 2 of its brief shall replace the corresponding Article 17.13(b) proposed by the union;

e) the employer’s language regarding standby pay (Article 18.03) as

set out on Tab 10, page 1 of its brief: f) the employer’s language regarding call back (Article 18.03) as

set out on Tab 10, page 3 of its brief; g) the employer’s language regarding shift premium (Article 18.04)

as set out on Tab 10, page 5 of its brief; h) the employer’s language regarding weekend premium (Article

18.05) as set out on Tab 10, page 6 of its brief; i) the status quo regarding transportation allowance (Article 18.07) as

described on Tab 10, page 8 of the employer’s brief. We remit to the parties the task of setting out this provision in language appropriate to the collective agreement;

j) the union’s proposal regarding vacations (Article 20.01) as set

out on pages 62 and 63 of its brief, except that employees will attain the 6th week vacation plateau after 22 years and the 7th week plateau after 28 years. We understand this provision to represent the status quo. Further, the employer’s proposal with respect to Article 20.09 (Tab 11, page 2 of its brief) is awarded except that that the employee must schedule the carryover week with his/her manager prior to

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March 31 of the carryover year instead of (as the employer proposed) prior to carrying over the week;

k) where there is disagreement regarding health and welfare benefits

(Article 21.01 and Article 21.10), we award the status quo. We remit to the parties the task of setting out this provision in language appropriate to the collective agreement;

l) the union’s proposal regarding part-time in lieu of benefits (Article

21.06) as set out on page 69 of its brief. We understand this language (subject to the amount of the percentage to be paid as referred to in paragraphs 3 and 4 on page 11 hereof) to represent the status quo;

m) the union’s proposal with respect to the setting of grid

compensation levels (Articles 25.02 and 25.03) as set out on pages 79 and 81 of its brief. We understand these provisions to represent the status quo;

n) the status quo with respect to the supply of lab coats (Article

21.01), as described on Tab 14, page 1 of the employer’s brief. We remit to the parties the task of setting out this provision in language appropriate to the collective agreement; and

o) add an Article 28.06 to read: “The hospital will supply the union with any existing job

descriptions in respect of bargaining unit jobs, and will update the union as new or amended bargaining unit job descriptions are created.”;

p) Lead Positions: All lead positions shall be paid an additional premium of

$1.40 per hour in addition to their regular rate of pay. This shall be a footnote to the salary grids. We understand this provision to represent the status quo;

q) Part-time Voluntary Benefits Part-time employees who currently participate in group health

and welfare benefit programs set out in Article 21.01 on a voluntary basis will be permitted to continue doing so. We direct the parties to set this out in language appropriate to a letter in the collective agreement;

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7. Any other matter as agreed between the parties. The effective date of these items will be the date of this award unless otherwise agreed between the parties.

The costs involved in this award:

Earlier in this award, we determined that the sum of $8,148.72 was available each year for improved or new non-wage benefits NOTE: The Board’s calculation of the non-wage increases in benefits in this award (based

upon the costing provided by the employer) is as follows: Pre-moderation annual cost Annual cost per 5 cents/hour (or per

.5% of providing in lieu)

$49,841.10 - Part time in lieu = $2,931.83 per .5% annually @ 8.5%//hour $9,640.02 – Afternoon/evening = $310.97 per 5 cents annually shift premium @ $1.55/hour $6,336.33 – Night shift premium = $204.40 per 5 cents annually @ $1.55/hour $11,582.12 – Weekend premium = $289.55 per 5 cents annually @ $2.00/hour $28,640.79 - Stand by pay = $477.35 per 5 cents annually @ $3.00/hour Accordingly in year 1 of the moderation period, the non-wage increases granted in paragraph 3 on page 11 hereof equal: $5,863.66 (increase of 1% in part time in lieu) $621.94 (increase of 10 cents in Afternoon/Evening Shift Premium) $613.20 (increase of 15 cents in Night Shift premium) $868.65 (increase of 15 cents in Weekend premium) $7,967.45 as opposed to an allowable increase of $8,148.72 (leaving $181.27 left over In year 2 of the moderation period, the non-wage increases granted in paragraph 4 on page 11 hereof equal:

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$2,864.08 (increase in stand-by pay of 30 cents) $2,931.83 (increase of .5% in part time in lieu) $621.94 (increase of 10 cents in Afternoon/Evening Shift Premium) $1,022.00 (increase of 25 cents in Night Shift premium) $868.65 (increase of 15 cents in Weekend premium) $8,308.50 as opposed to an allowable increase of $8,329.99 (including the $181.27

left over from the previous year) (leaving $21.49 left over)

The Board was not advised, and does not believe, that the matters set out in paragraph 6 on pages

12 and 13 of this award entail any additional cost to the employer.

Any proposal not specifically included herein is rejected.

The board retains jurisdiction over this award until a new collective agreement is executed.

DATED at Toronto, this 20th day of July, 2020.

__________________________________

John McNamee, Chair

I dissent as attached “Brian O’Byrne”___________

Brian O’Byrne, Employer Nominee

I dissent as attached “Larry Robbins”____________

Larry Robbins, Union Nominee

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IN THE MATTER OF AN ARBITRATION BETWEEN:

GROVES COMMUNITY MEMORIAL HOSPITAL

and

OPSEU LOCAL 236

RE: LABORATORY EMPLOYEES

H.L.D.A.A.

DISSENT

I have reviewed the Award of the chairperson in this matter. There are many aspects of this

award I can concur with; others where I would have awarded differently.

However, the key problem with this award for the employees is that they will continue to receive

wages which are below industry standards. Yet I can’t fault the chairperson for finding that as a

board we are bound to follow Bill 124. As an aside I do agree with the manner in which the

chairperson has interpreted Section 11(3) of the Act. My real issue is with the Ford Government.

These employees have decided to organize and to join OPSEU so that they might bring their

compensation levels up to industry standards. At present, their wages are significantly below

their provincial counterparts. However, as a result of Bill 124, not only do they fail to catch up or

even get closer to provincial wage levels, they actually fall further behind. They will be receiving

wage increases of 1% per year while those covered by the Central Hospital Agreement are

receiving increases of 1.75% per year.

There was no reasonable justification in my view for this Government’s actions in interfering in

the collective bargaining process. It’s not only a setback for the employees affected, it also plays

havoc with provincial bargaining. It’s been made even worse by the timing when Hospital

employees are on the front lines during the COVID 19 pandemic. This Government may claim to

be appreciative of the role Hospital workers are currently playing. But actions speak louder than

words and this legislation is a slap in the face to these employees.

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Unfortunately. this particular bargaining unit has had their expectations for a reasonable increase

in compensation put on hold until some future date. In my view, the continuing disparity in

compensation and wages and the damage inflicted by the Government’s actions needs to be

addressed as soon as possible.

Respectfully Submitted,

DATED AT TORONTO, this 19th day of July, 2020

“Larry Robbins”

Larry Robbins, Union Nominee

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