--000000000000192cad061debfa97 Content-Type: multipart/alternative; boundary="000000000000192cad061debfa96" --000000000000192cad061debfa96 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable I followed up with our outside Canadian counsel and am waiting to hear back. I'll provide an update as soon as we get an update. On Tue, Jul 23, 2024 at 6:02=E2=80=AFAM Timon Page = wrote: > Good morning Steve > > Just circling back to see if we have received a definitive answer on the > temporary help agency licence requirement from our Canada counsel. > > Best regards, > > Timon Page > General Manager, Ontario > *Please note my email address has changed:* > timon.page@thekey.com > Mobile: (437) 223-0841 > TheKey.com > > > > On Mon, Jul 8, 2024 at 4:54=E2=80=AFPM Steve Koyanagi > wrote: > >> Yes; I pinged our Canada counsel and will let you know what we find out. >> >> On Mon, Jul 8, 2024 at 1:53=E2=80=AFPM Timothy Thomas wr= ote: >> >>> It=E2=80=99s very nuanced. >>> >>> Steve can we get local council to assist here? If it does in fact cover >>> private home care than we will need to funnel our revenue and clients >>> through the Waterloo entity until this is resolved. >>> >>> In addition there appears to be rules governing our client consent and >>> employment agreements which would need to be updated. >>> >>> Tim Thomas >>> Head of Canada Division >>> *Please note my email has changed:* >>> tt@TheKey.com >>> (514) 591-9387 >>> TheKey.ca >>> [image: TheKey] >>> >>> >>> On Mon, Jul 8, 2024 at 9:17=E2=80=AFPM Amanda Fults >>> wrote: >>> >>>> @Sean Cygan what does this email clarify? Is it >>>> saying that under our business as a home care agency we have to have t= he >>>> THA license? >>>> >>>> On Mon, Jul 8, 2024 at 3:14=E2=80=AFPM Sean Cygan = wrote: >>>> >>>>> FYI - >>>>> >>>>> Dear Sean Cygan, >>>>> >>>>> >>>>> >>>>> Thank you for your inquiry. >>>>> >>>>> >>>>> >>>>> Temporary help agencies and recruiters are required to have a licence= . >>>>> These terms are defined in the ESA and its regulations. >>>>> >>>>> >>>>> >>>>> Every legal entity that operates as a temporary help agency or acts a= s >>>>> a recruiter must apply for a licence. This is the case even if the se= parate >>>>> legal entities are treated as one employer under section 4 of the ESA >>>>> . >>>>> >>>>> >>>>> >>>>> A *temporary help agency* is an employer that employs persons for the >>>>> purpose of assigning them to perform work on a temporary basis for cl= ients >>>>> of the employer. >>>>> >>>>> Clients of a temporary help agency are people or entities that enter >>>>> into an arrangement with a temporary help agency in which the tempora= ry >>>>> help agency agrees to assign, or to try to assign, one or more of its >>>>> =E2=80=9Cassignment employees=E2=80=9D to perform work for that perso= n or entity (=E2=80=9Cthe >>>>> client=E2=80=9D) on a temporary basis. >>>>> >>>>> Learn more about what is a temporary help agency under the ESA >>>>> >>>>> .