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A priority for our organization is to make timely and substantive submissions on matters of public policy interest to its membership.  The Board regularly monitors developments in the judicial, legislative and regulatory arenas at both the provincial and the federal level looking for opportunities to make a constructive and valuable contribution on behalf of our members and clients.

Public policy engagement has included interventions in judicial proceedings at the Supreme Court of Canada, and submissions and appearances, including to Parliamentary and Legislative Committees, Government Departments and Ministers.  CACE regularly collaborates with other key employer stakeholders.

 A list of our Submissions and Interventions are listed below. Copies of our Submissions and Interventions are available to our members only.  To access, please login, then click the down arrow in  the Advocacy Committee heading, then click on Submissions and Interventions.

To join the Committee, please email our Executive Director, Tracy Scanks at  .

CACE Submissions & Interventions

Supreme Court of Canada Denies Leave to Appeal in Battiston v. Microsoft Canada Inc.: Electronic Box Consents Provide Enforceable Agreement Limiting Incentive Compensation During Notice - July 28, 2022

CACE Submissions re CHRT Pay Equity Act Rules and Forms - May 11, 2022

CACE Memorandum of Argument on an Application for Leave to Intervene - Gibraltar - May 6, 2022

NS - CACE Submissions re Employer Backstop for COVID-19 Vaccination Policy - Feb 8, 2022

CACE Advocacy Committee Submissions Federal Mandatory Vaccinations - December 12, 2021

CACE Submission on Bill 27 - Working for Workersd Act - ON - November 22, 2021

CACE Submission - Consultation - Ontario's Workforce Recovery Advisory Committee - July 30, 2021

CACE Submissions to Ministry of Public Safety re Vaccinations July 27, 2021

CACE Waksdale v. Swegon Submissions prepared by Advocacy Committee - May 11, 2021

CACE Human Rights Tribunal of Ontario Stakeholder Consultation Submissions - May 7, 2021

COVID-19 Pandemic and Ontario Employers; Further Amendments or Regulations to the Employment Standards Act, 2000 Submission to the Minister of Labour - February 16, 2021

Submission regarding Federal Pay Equity Regulations - January 13, 2021

CACE letter to Minister McNaughton re Further Amendments or regulations to the Employment Standards Act, 2000 - Nov. 24, 2020

Northern Regional Health Authority v. Linda Horrocks - Factum of the Intervener (CACE) - October 13, 2020

Submission to BC Labour Relations Board re Great Canadian Casinos Inc. - August 31, 2020 - CACE provided a submission to the BC Labour Relations Board with respect to the Charter challenge to the B C Labour Relations Code picketing restrictions.

Nova Scotia Employment Standards – August 19, 2019 – CACE provided a submission in response to a stakeholder consultation in connection with potential amendments to the Labour Standards Code to address the wage gap based on gender and other protected groups.

Federal Privacy Consultation – August 1, 2019 – CACE presented a submission in response to the restated consultation in regard to whether or not consent is required before an organization can transmit personal information across borders.

Federal Pay Equity – June 28, 2019 – Submission regarding the proposed regulations supporting the newly enacted federal Pay Equity Act.

Federal Labour Program – February 15, 2019 – Submission regarding the proposed regulations supporting changes to the Canada Labour Code regarding compliance and enforcement.

Alberta Labour Relations Board – January 21, 2019 - Submission to the Board regarding its review of its policy regarding the “Build-up Principle”.

British Columbia Human Rights Tribunal – January 14, 2019 – Submission in response to the Tribunal’s review of its policies regarding privacy, transparency and freedom of expression.

British Columbia Labour Relations Code review – December 1, 2018 - Submission to BC Code Review Panel regarding its review of the Code and several recommendations that would benefit organized labour.

Saskatchewan review of Workplace Impairment – August 31, 2018 – Submission with regard to opportunities for legislative reform to enhance workplace safety following the legalization of recreational cannabis.

British Columbia Employment Standards – August 31, 2018 – Submission to the BC Law Institute in response to its recommendations following its review of the Employment Standards Act.

Federal Labour Standards and Health and Safety - March 30, 2018 – Submission to the federal government in response to its consultation regarding the implementation of amendments to the Canada Labour Code in connection with the compliance and enforcement provisions under Parts II and III.

British Columbia Labour Relations - March 20, 2018 – Submission to the B.C. review panel looking into potential amendments to the Labour Relations Code.  

Nova Scotia Labour Relations - January 31, 2018 – Submission to the Nova Scotia Labour Board in response to its Review of the Labour Board’s Policy on Casual Employees.

Ontario Employment Standards - December 23, 2017:  Submission to the Ontario government regarding its review of exemptions from various employment standards, including hours of work, in respect of Managers and Supervisors, and Information Technology Professionals.

British Columbia Human Rights - Nov 17, 2017. Submission in response to the provincial government’s consultation process with respect to the implementation of a Human Rights Commission.

Alberta Occupational Health and Safety – October 2017. CACE made submissions in connection with the Alberta Occupational Health and Safety System review. 

Ontario Employment Standards – July 2017CACE made submission on Bill 148 (Fair Workplaces, Better Jobs Act). 

Federal Labour Standards – June 2017. CACE responded to a request from the Federal Labour Program to update CACE’s previous positions in respect of potential updates to Part III of the Canada Labour Code

Changes to Compassionate Care Leave and Child Care Leave – June 13, 2017CACE made written submissions to the federal Finance Department in response to the proposed amendments to the Canada Labour Code and the Employment Insurance Act to implement changes announced in the Federal Budget to extend child care leave and compassionate care leave.

Alberta Labour Relations Code - April 2017 CACE provided submissions in response to the Government’s consultation in connection with amendments to the Labour Relations Code in April, 2017. 

Submissions to Nova Scotia’s Chief Appeal Commissioner of the Workers Compensation Appeals Tribunal – December 2016.  CACE made submissions on the proposed changes to the Workers Compensation Appeal Tribunal Regulations. 

British Columbia Teachers' Federation v Her Majesty the Queen in Right of the Province of BC, 2015 BCCA 184 (36500) – Intervention – November 2016.  The case involved an interpretation of the 2015 SCC Labour Trilogy and the question of the extent to which pre-legislative consultation can affect the constitutionality of legislation that limits collective bargaining on certain issues. 

Alberta Essential Services legislation – October 2016.  CACE provided written submissions to the Alberta Government in response to its review of this legislation.  

Ontario Changing Workplace Review – October 2016.  CACE provided a submission to the Special Advisors appointed by the Ontario Minister of Labour to review the changing nature of the workplace in response to their Interim Report.  The review is considering how the Labour Relations Act, 1995 and Employment Standards Act, 2000 could be amended to best protect vulnerable workers in precarious employment, while supporting businesses in Ontario’s changing economy.  Earlier in the review process, in response to an invitation from the Special Advisors, Ontario CACE Directors Jeff Murray and Lorenzo Lisi made a verbal submission. 

Proposed Right to Request Flexible Work Arrangements under the Canada Labour Code – July 2016.  CACE made written submissions to the Federal Minister of Labour in respect of a review of the Canada Labour Codeand the proposed amendment to enact a right of employees to request flexible work arrangements. 

Proposed Proactive Pay Equity Legislation in the Federal Sector – May 2016.  In response to an invitation from the Parliamentary Special Committee on Pay Equity, CACE provided submissions on a host of proposed changes to the federal pay equity system including the implementation of proactive pay equity legislation. 

Bill S-201 on Genetic Discrimination Submissions – March 2016.  CACE was invited to make submissions on a revised Bill S-201, which addressed the issue of discrimination on the basis of genetic testing.  Karen Jensen (Chair of the Advocacy Committee) made written submissions on CACE’s behalf.  CACE had previously testified before the Senate Human Rights Committee in relation to this legislation in a previous incarnation in 2014. 

Written Submission to Standing Committee on Alberta’s Economic Future - February 2016.  A written submission was filed on the Committee’s review of the Personal Information Protection Act, SA 2003, c P-6.5 (“PIPA”). 

Wilson v Atomic Energy Canada – January 2016.  CACE and FETCO combined to intervene in this very important federal employment case before the Supreme Court of Canada.  The case involved the question of whether federally regulated employers can dismiss an employee without cause, pay them reasonable notice and not face a complaint of unjust dismissal under s. 240 of the Canada Labour Code

Written Submission to Alberta Government on Essential Services Legislation in Alberta –October 2015.  The Alberta CACE members Working Committee filed a written submission to the Alberta Government on the Essential Services Legislation in Alberta. 

Agenda and Speaking Notes The Canadian Standing Senate Committee on Human Rights - September 29, 2014. Submitted by Karen Jensen

Submissions on the Alberta Employment Standards Code Review – 2014.  CACE participated in consultations and made submissions regarding the Alberta Employment Standards Code Review. 

Bernard v Canada (Attorney General), 2014 SCC 13 – Intervention – 2013. CACE made submissions to the Supreme Court of Canada as an intervener. 

United Food and Commercial Workers, Local 503 v Wal Mart Canada Corp, 2014 SCC 45 – Intervention – July 2013.  CACE made submissions to the Supreme Court of Canada as an intervener. 

R. v Cole, 2012 SCC 53  – Intervention – 2012. CACE made submissions to the Supreme Court of Canada as an intervener. 

Letter to Jean Francois Lafleur re Bill C-377 - November 21, 2012 

Submission to Ontario Minister of Labour on Critical and Fatal Injuries to 'Persons' Who Are Not Workers - Oct 16, 2012 

Can Employees Expect Pornography on a on a Work Computer to be Private – May 3, 2012 

Submissions on the legislatively mandated Ontario Human Rights Review – 2012.  CACE made submissions on the legislatively mandated Ontario Human Rights Review. 

Submission to the Canadian Standards Association on the Draft Standard on Psychological Health and Safety in the Workplace - January 2012 

Submissions to the Saskatchewan Labour Relations Board – 2011.  CACE made submissions to the Saskatchewan Labour Relations Board on draft amendments to the Board’s procedural rules and forms as created under section 17.1 of the Saskatchewan Trade Union Act.

Submission to the Canadian Human Rights Tribunal – July 2011.  CACE made submissions to the Canadian Human Rights Tribunal regarding changes to the Tribunal’s procedures. 

Submissions to the Law Amendments Committee of the Nova Scotia Legislature on Bill 100 – 2010.  CACE made submissions to the Law Amendments Committee of the Nova Scotia Legislature on Bill 100, An Act to Establish a Unified Labour Board

Submission on Ontario Ministry of Labour’s Consultation On Work through Temporary Help Agencies - July 7, 2008 

Submissions on work stoppages in the federal private sector – 2008.  CACE made submissions to the federal Minister of Labour in connection with his study of work stoppages in the federal private sector. 

Submissions on reforming the Saskatchewan Trade Union Act – 2008.  CACE made joint submissions with the Saskatchewan Chamber of Commerce to the Minister of Advanced Education, Labour and Employment on reforming the Saskatchewan Trade Union Act. 

Submission to Nova Scotia Environment and Labour on Violence in the Workplace - Feb 15, 2007

CACE Submission to the Standing Committee on Human Resources, Social Development and the Status of Persons with Disabilities -10-Feb 7, 2007 

Submissions on Bill C-257 (use of replacement workers in the federal sector) – 2005.  CACE made submissions to the Standing Committee on Human Resources, Social Development and the Status of Persons with Disabilities on Bill C-257 (the use of replacement workers in the federal sector). 

Submission to the Federal Labour Standards Review Commission- 2005-10-14 - Submitted by: CACE Legislation and Law Reform Committee 

Submissions on the review of Part III of the Canada Labour Code – 2005.  CACE made submissions to the federal Labour Standards Review Commission in support of its comprehensive review of Part III of the Canada Labour Code. 

Submissions on the reform of the Pension Benefits Standards Act – 2005.  CACE made submissions to the federal Minister of Finance on the reform of the Pension Benefits Standards Act, 1985. 

Submissions on the Budget Measures Act, 2004 (No 2) – 2004.  CACE made submissions to the Ontario Minister of Finance on the Budget Measures Act, 2004 (No 2), which introduced the Ontario Health Premium.

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