May 11, 2015

Senator Bob Runciman Chair, Senate Committee of Legal and Constitutional Affairs The Ottawa, ON K1A 0A4

Dear Senator Runciman:

Re: Bill C-377 − Income Tax Act amendments (requirements for labour organizations)

Please find attached the submission by the International Brotherhood of Electrical Workers (Canada).

We have reviewed statements and reports on Bill C-377 by several witnesses that have appeared before Senate Committee hearings and utilize some of that information in our submission.

Our submission introduces your members to our organization, outlining who we are, what our objectives are, where you would find our members working throughout Canada, as well as our position and concerns with this Bill.

Our objective with this submission is to assist your committee and its members on making an informed decision and giving you a glimpse of how this legislation would negatively impact our members of the International Brotherhood of Electrical Workers in Canada.

Sincerely,

Bill Daniels International Vice President IBEW First District – Canada

Encl.

BD/ln

Submission to the Senate of Canada

Standing Committee on Legal & Constitutional Affairs

RE: Private Members Bill C-377, An Act to Amend the Income Tax Act (Requirements for Labour Organizations)

Submission By: The International Brotherhood of Electrical Workers Date: May 11, 2015

Who is the International Brotherhood of Electrical Workers?

The International Brotherhood of Electrical Workers (IBEW) officially began November 28, 1891, making 2013 our 122nd year as a union. The IBEW represents over 680,000 electrical workers in North America. The IBEW represents over 65,000 of those members in over 85 local unions from Coast to Coast right here in Canada. The IBEW represents workers in a wide variety of fields, including utilities, construction, telecommunications, broadcasting, manufacturing, railroads and government.

We have local union offices located in all ten provinces and currently one territory. We have members working from Victoria, British Columbia, to St. John Newfoundland, and from Point Pelee, to some of the most northern and remote places in our country. We represent members that are spread across four different generations from traditionalists to generation Y, males and females, and from various backgrounds, cultures and religions.

Declaration of the International Brotherhood of Electrical Workers

Our cause is the cause of human justice, human rights, human security.

We refuse, and will always refuse, to condone or tolerate dictatorship or oppression of any kind.

We will find and expel from our midst any who might attempt to destroy, by subversion, all that we stand for.

This Brotherhood will continue to oppose communism, Nazism, or any other subversive “ism”. We will support our God, our Nations, our Union.

Objectives

The objects of the International Brotherhood of Electrical Workers are:

 To organize all workers in the entire electrical industry in the United States and Canada, including all those in public utilities and electrical manufacturing, into local unions.  To promote reasonable methods of work,  To cultivate feelings of friendship among those of our industry,  To settle all disputes between employers and employees by arbitration (if possible).  To assist each other in sickness or distress,  To secure employment,  To reduce the hours of daily labour,  To secure adequate pay for our work,  To seek higher and higher standard of living,  To seek security for the individual,  And by legal and proper means to elevate the moral, intellectual and social conditions of our members, their families and dependents, in the interest of a higher standard of citizenship.

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Where would you find our members working?

IBEW members are found in various sectors across Canada. Many of our members are responsible for providing electricity to schools, hospitals, nursing homes, hotels, casinos, oil sands projects, automotive plants, ships, and airplanes. We have members troubleshooting assembly lines at hundreds of manufacturers across the country. We are the men and women who keep the lights on!

We have members that are employed by NAV Canada, the Canadian Coast Guard, BC Hydro, SaskPower, NB Power, Nova Scotia Power, Manitoba Hydro, CN Rail, CP Rail, Transit Rail, Canada’s largest construction and electrical contractors, all the way down to small “mom & pop” electrical contractors across the country. We also have members working here on Parliament Hill updating electrical systems in the nation’s capital.

Did you have the opportunity to watch tightrope walker Nik Wallenda make history on June 16, 2012 as he crossed high above Niagara Falls in front of a live international television audience? If so, what you didn't see that night was just how much work went into ensuring that his cable was safely secured on both the American and Canadian sides of the falls. Nik Wallenda hand selected the IBEW unionized workers to ensure that the cable he would use to cross over Niagara Falls was safely & properly installed. Putting his life in the hands of our highly trained members.

Structure of the IBEW

The IBEW, like many other unions, is considered a very democratic organization. Every three (3) or four (4) years, depending on Local Union by-laws, IBEW members elect their Local Union leadership for the following positions:

 President  Vice-President  Recording Secretary  Treasurer  Business Manager/Financial Secretary  Executive Board (No more than 7 nor less than 3 members)  Delegates to the International Convention

The above elected IBEW Local Union members must swear by the following oath prior to officially becoming an officer of the Local Union:

“I _____(Name)____, do sincerely pledge on my honour to perform the duties of my office as prescribed by the Constitution and bylaws of this organization. I will deliver to my successor in office all books, papers, and other property of this organization that may be in my possession at the close of my term. I will also deliver all such property to the International President upon his demand. All of this I solemnly promise with the full knowledge that to violate this pledge is to stamp me devoid of principle and destitute of honour.”

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Delegates to the International Convention are responsible for voting on amendments to the Constitution as well as electing the following positions:

 International President  International Secretary-Treasurer  Eleven District Vice-Presidents*  Eight International Executive Council Members*

*Delegates are only eligible to vote for their own District Vice-President and International Executive Council Members.

The above elected IBEW members must swear by the following oath prior to officially becoming an International Officer of the IBEW:

“I, _____(Name)______, do hereby solemnly pledge on my honour, that I will faithfully discharge my duties as an officer of the International Brotherhood of Electrical Workers. I will support by every means within my power its Constitution, and I will enforce it to the best of my ability. At the expiration of my term of office, I shall deliver to my successor all books, papers, money and other property in my possession belonging to the I.B.E.W. or its Local Unions; and I shall not be relieved from any bond or obligation unless and until I comply with this law.”

Below is a chart that visually lays out Organizational structure of the IBEW for your reference.

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International Constitution — The Law of the IBEW

The IBEW Constitution contains more information about the Brotherhood than any other single document. It sets forth the purpose, the philosophies, and the structure of the union; the laws by which its members are governed; and the rights and obligations of its members.

It is the Brotherhood’s supreme law; but it is not inflexible and may, when necessary, be amended by action of the membership.

Duties of Local Union Officers (pertaining to union funds)

Elected members of the IBEW must strictly adhere to our IBEW Constitution which clearly lays out the duties & reporting procedures for financial disclosure to our members, from the Local Union elected leadership to the International President.

Article XVII – Duties of Local Union Officers

President

Sec. 1. The Local Union President shall be held responsible for the strict enforcement of this Constitution and the rules herein and the Local Union bylaws. He/she shall be held personally liable and subject to penalty by the International President for failure to conduct orderly meetings or failure to carry out the responsibilities and duties imposed upon him herein.

(f) He/she shall either appoint an auditing committee of three members, or he or the Local Union Executive Board, as the Local Union decides, shall employ a public accountant to reconcile the books and accounts of the Local Union every three months. He shall inspect the bank book or books of the treasurer to see that Local Union moneys turned over to the treasurer have been properly and promptly deposited in the name of the Local Union.

In addition, he/she shall employ a certified public accountant to perform an annual independent audit of the books and accounts of the Local Union, in accordance with United States generally accepted auditing standards or their international equivalent; provided, however, should the Local Union believe it would be cost prohibitive to conduct such an annual independent audit, the Local Union can request a waiver from the International Secretary Treasurer.

(g) He/she shall see that all funds of the Local Union are deposited in a reputable bank or banks in the name of the Local Union, subject to withdrawal by check signed in the name of the Local Union and countersigned by the president and treasurer, and see that no disbursements are made except on an order countersigned by the Recording Secretary and himself/herself (President) after action of the Local Union. However, no action of the Local Union is necessary to pay regular or standing bills such as rent, salaries, and payments due to the International Secretary Treasurer.

(h) He/she shall notify in writing any bank, or all banks, in which the Local Union makes deposits, that the Local Union empowers the International President to stop withdrawal of any Local Union funds when in the judgment of the International President such action is necessary to protect the Local Union and its members. He/she shall notify such bank or banks that they are to honour and abide by any notice from the International President to

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stop withdrawals should the occasion arise. He/she shall send to the International Secretary- Treasurer a copy of such letter or notice to any bank or banks to be made a matter of record.

Vice-President

Sec. 2 The Vice-President shall assist the president in the discharge of his duties and shall fill his place in case of the president’s absence and perform such other duties as are required by this Constitution and the bylaws of the Local Union.

Recording Secretary

Sec. 3 The Recording Secretary shall keep correct minutes of each meeting of the Local Union, answer all correspondence in accordance with instructions given him by the Local Union or the president, make out all orders on the treasurer for the payment of authorized bills, notify the International Secretary-Treasurer of all changes in officers giving names and addresses, and perform such other duties as are directed by the president or required by this Constitution and the bylaws of the Local Union.

Financial Secretary

Sec. 4 The Financial Secretary shall keep such books and records, and issue such receipts, as are required or approved by the International Secretary-Treasurer. He/she may, when necessary and when approved by the Local Union, employ an assistant or assistants. He/she shall be responsible for all moneys collected by the Local Union until such funds are turned over to the Treasurer or deposited in the Local Union’s bank account without delay. When he/she deposits any Local Union funds, he/she shall furnish the treasurer with the bank record of all such deposits not later than the close of the month. He/she shall make known to the Local Union the receipts received at such time as the Local Union decides. He/she shall mail to the International Secretary Treasurer the per capita report, and the money due, by the tenth (10th) of the month, unless special arrangements with the International Secretary-Treasurer are made. (The Local Union shall be responsible to the International Secretary-Treasurer for such payments.) If the Financial Secretary fails to do this as required, the Local Union may be assessed an amount determined appropriate by a policy developed by the International Secretary-Treasurer. He/she shall keep a record of each member, the full name and address, and notify the International Secretary-Treasurer of all suspended or expelled members.

Sec. 6 The Financial Secretary shall submit his books and records for the inspection or audit when called upon by the International President, the International Secretary-Treasurer, the Local Union President, or Executive Board.

Treasurer

Sec. 7 The treasurer shall receive from the Financial Secretary all moneys collected or the bank record of money deposited in the Local Union’s bank account and give proper receipt for the same. He/she shall deposit all Local Union money’s turned over to him/her by the Financial Secretary in a bank or banks designated by the Local Union in the name of the Local Union. He/she shall make no disbursements without sanction of the Local Union, except for payments of regular or standing bills such as rent, salaries and payments to the International Secretary-Treasurer which do not require a vote of the Local Union and upon an order or warrant signed by the President and Recording Secretary. He/she shall make an itemized statement to the Local Union as

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and when required by the Local Union or the President. He/she shall submit his books and records for inspection or audit when called upon by the International President, the International Secretary-Treasurer, the Local Union President or Executive Board.

Duties of International Officers (pertaining to union funds)

Article IV – International President

Sec. 3 (f) To authorize in writing any International Vice-President to audit the books and records of any Local Union in his district or to engage an accountant for the purpose, whenever he deems such action necessary for the protection of the Local Union and its members.

Article VI – International Secretary-Treasurer

Sec. 1 The duties of the International Secretary-Treasurer shall be:

To keep correct records of the proceedings of the International Convention and preserve all important papers of the IBEW business; to deposit all funds in a bank or banks approved by the International Executive Council, in the name of the IBEW. All deposits and withdrawals shall be subject to the signature of the International Secretary-Treasurer.

To prepare for publication in the IBEW’s official monthly publication each year the annual IBEW audit by the certified public accountant employed by the International Executive Council.

Article VIII – International Executive Council

Sec. 1 The duties of the International Executive Council shall be:

To meet quarterly; to employ a certified public accountant who shall audit all the books and accounts of the International Officers, on an annual basis, at the end of the fiscal year; to act on all applications for pension, disability, or retirement benefits; to determine all proposed Constitutional amendments submitted for referendum vote; and to attend to all business properly brought before it.

Sec. 7 To take charge of, i.e., impose a trusteeship on, the affairs of any Local Union when its judgment such is necessary to protect or advance the interests of its members and the IBEW, and to suspend any local officer or member who offers interference in such cases. Sec. 10 The minutes and report of each International Executive Council meeting shall be published in full in the IBEW’s official monthly publication.

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Article XVIII – Dues – Assessments – Funds

Sec. 4 All disbursements must be on an order drawn on the treasurer signed by the president and recording secretary. However, no action of the Local Union is necessary for payment of regular or standing bills such as rent, salaries, and payments to the International Secretary- Treasurer.

Sec. 5 The funds and property of a Local Union shall be used only for such purposes as are approved by the International President, or as are specified in this Constitution and as many be necessary to transact, properly manage and conduct its business.

Sec. 7 The funds and property are for the legitimate purposes of the Local Union while five (5) members remain therein. Should a Local Union finally dissolve, its charter, books, papers and funds shall at once be forwarded to the International Secretary-Treasurer.

How does the IBEW Local Unions spend their money?

As you can see, the IBEW like several other unions has many democratic procedures before money is spent. Our members vote on how they decide to utilize their money. They elect members to run their local unions, and if those elected members are not doing the job to the satisfaction of the membership, chances are they won’t be re-elected for another term.

Our IBEW Local Unions are required to have regular monthly meetings to discuss the business of the Local Union which can be broken down as follows:

 Opening  Reading of and approval of the previous meeting minutes  Review all Communication and Bills  Reports of Executive Board and Officers o Business Managers Report  Proposition for Membership  Reports of Delegates and Committees  Unfinished Business  New Business  Good of the Union  Review of all Receipts and Expenses  Closing

Members may question any and all above items during the meeting so that discussion is recorded in the meeting minutes. In reviewing our financials there is some variances on how our Local Unions provide this to our membership, but the majority of our 85 Local Unions have their Treasurer provide their report on an overhead screen, many of our locals also hand out the financial report to each member attending the general meeting. Members who were not able to attend the meeting may request to see that report and ask any questions similar to those who were in attendance at the meeting.

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What is the reason for Private Members Bill C-377, and who is asking for it?

MP Russ Hiebert states on his website www.c377.ca the following:

“Under this bill, every labour union in Canada will be required to file a standard set of financial statements each year. Details from those statements will be posted on a public website for Canadians to examine. The public will be empowered to gauge the effectiveness, financial integrity and health of Canada’s unions”

Currently there are 8 jurisdictions in Canada where there are already existing provincial and federal laws that require trade unions to be democratically accountable to their membership.

By law, trade unions like the IBEW are democratically governed organizations whose members elect their own leaders and hold them accountable. The IBEW is not opposed to transparency or accountability, contrary to the claims of some of the bill’s proponents. As you can see outlined above, our IBEW Constitution is built on being accountable to the membership.

As outlined earlier, the IBEW Constitution as well as federal and provincial labour laws in seven of Canada’s ten provinces already require unions to issue financial reports and make them available to members. The federal government and seven of Canada’s ten provinces require unions to produce annual financial statements, and make those statements available to the union members. Only three (3) provinces, Alberta, Saskatchewan, and Prince Edward Island do not have labour laws requiring this, but are looking at implementing provincial labour laws similar to other fellow provinces.

There is only a very small fraction of the nearly 4.5 million union members in Canada who have filed a complaint regarding their ability to view their union’s financial reports. According to the provincial labour relations board reports, in2010-2011, there were zero complaints filed by union members regarding union financial reporting in Manitoba, New Brunswick, and Nova Scotia. In Ontario, there were five complaints, and in the federal jurisdiction, two complaints (both of which were withdrawn). British Columbia had only one complaint filed in 2011.

Of all those complaints listed above, they represent 0.00002% of the nearly 4.5 million union members in Canada. While it is very important that those cases are properly dealt with and those members receive the financial information they are entitled too, this is not cause for a national public policy concern, nor a reason to implement a large onerous union-registry at a cost to the Canadian Tax payer.

The IBEW is deeply concerned over the public reporting of the vast amounts of information required by this legislation and who, and what, they might use this information for.

There are thousands of examples, but let’s just explore a few.

IBEW members

IBEW members could access the information contained in this bill via the internet to look up the health of the union funds, how much their Business Manager, President, or anyone employed by the Local Union earns, how much their local union pays to have their grass cut, or the driveway cleared of snow. They can gauge how healthy their training and education fund is, or how much time was spent meeting with any politician whether it’s a city councilor, a provincial politician, or a federal politician even though this is already captured by Provincial and Federal lobbyist registry’s.

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Joe Public (Anyone in the world with internet access)

Would be able to access this information for whatever reason(s) they choose to use it for.

Merit Canada

Merit Canada, any of their eight affiliated provincial open shop (non-union) construction associations, can harvest this information and use it as a competitive advantage in the Construction sector. Merit along with any of their employers will be able to see how strong the IBEW training funds are in IBEW Local 353 Toronto or IBEW Local 424 Alberta for example. They will be able to determine how any of the 85 IBEW Local Unions spend their time (organizing, bargaining, on grievances, or for political or lobbying activities), how much those unions pay their leaders, even if they are paid less than then $100,000 threshold mentioned in section 149.01 – 3,(b),vii. Merit and their contractors are our competitors, and therefore will gain a competitive advantage in the construction or any of the various sectors & industries that the IBEW is involved in. They will be able to do this for any other labour organization as well.

LabourWatch

The IBEW believes that LabourWatch Canada and their “Board Members” will have the most to gain from this legislation.

According to their website, LabourWatch is organization that seeks to “advance employee rights in labour relations.” and “to help employees make informed choices.” They assist employees in deciding whether or not to join a union. Their website provides information and links on:

 Unions for employees who want to become or remain unionized.  How to cancel a Union card during a Union-organizing campaign.  How to decertify a Union.  How to file an Unfair Labour Practices complaint against a union.  News on emerging labour relations developments on the Internet.

According to LabourWatch Canada’s website, their Board of Directors clearly has no representation from labour unions, only those organizations that would like to remain/operate their business in a union free environment:

 Luc Beaulieu Conseil du Patronat du Québec  Satinder Chera Director Provincial Affairs - Ontario Canadian Federation of Independent Business  Jim Cormier Director, Atlantic Canada, Retail Council of Canada  Luc Erjavec Vice President, Atlantic Canada, Canadian Restaurant and Foodservices Association  Harvey Miller Executive Director, Merit Contractors Association  John Mortimer President, Canadian LabourWatch Association LabourWatch would be able to harvest information that has been scrutinized by the Canadian Revenue Agency, paid for by the Canadian tax payers, and provided free of charge on a government of Canada website. LabourWatch will be able to use this information during union organizing drives to discourage employees from joining a union, whether that union is the IBEW, UFCW, Unifor or others.

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How could LabourWatch use this information? Let’s look at the following two examples of what could happen here in Canada if Bill C-377 is passed into law. This scenario happens quite frequently to our IBEW Local Unions and their organizers in the United States (and to other unions as well).

Scenario 1: A small IBEW Local Union in Ontario consisting of less than 100 members seeks to organize an electrical contractor (we will call this Contractor ABC), in their geographical jurisdiction. This IBEW local union has complied with the requirements of Bill C-377 and therefore has all of the information required by the Bill posted for the public to see on a government of Canada website. The organizer has been talking to employees of ABC and most of them would like to join the IBEW. The owner hears that his employees have been approached by the IBEW and are thinking of joining the union and therefore they would be represented under the collective bargaining agreement and ABC would become a signatory union contractor. ABC decides to contact LabourWatch Canada to inform them of the unionization drive. LabourWatch Canada will then provide to ABC a vast amount of information and opinions on how to deter the employees from joining the IBEW. One of the tactics that is quite often used in the United States by organizations similar to LabourWatch is to tell employees of ABC that this small IBEW Local Union has less than 100 members and therefore has very little in union funds, or very little or no strike fund, or the IBEW only wants you to join to help them pay their bills and that these ABC employees will have no representation. In other words this union is too small, runs on a shoe-string budget and won’t be able to help you and they might even put your company ABC out of business. We hear this consistently from our organizers from all fifty US states.

Scenario 2:

A larger IBEW Local Union in Alberta consisting of 9,000 members seeks to organize an electrical contractor (we will call this Contractor XYZ), in their geographical jurisdiction. This IBEW local union has complied with the requirements of Bill C-377 and therefore has all of the information required by the Bill posted for the public to see on a government of Canada website. The organizer has been talking to employees of XYZ and most of them would like to join the IBEW. The owner hears that his employees have been approached by the IBEW and are thinking of joining the union and therefore they would be represented under the collective bargaining agreement and XYZ would become a signatory union contractor. XYZ decides to contact LabourWatch Canada to inform them of the IBEW’s unionization drive. LabourWatch Canada will then provide to XYZ a vast amount of information and opinions on how to deter the employees from joining the IBEW. One of the tactics that is quite often used in the United States by organizations similar to LabourWatch is to tell employees of XYZ during the unionization drive that this large IBEW Local Union has so many members that they will just be a number, that the IBEW only wants to increase their union funds, or the union only wants you to join them to help them pay their bills and fat cat union boss salaries, and that there are too many union reps but that these XYZ employees will have no representation because the union reps are busy helping their friends. In other words this union is too big,

The International Brotherhood of Electrical Workers, First District (Canada) Page 11 runs on a massive budget and won’t be able to help you and they might even put your company XYZ out of business. That was the complete opposite of the first scenario and again this is something that we hear consistently from our organizers from all fifty US states. The passage of this bill could create a BIG boom in business for an organization like LabourWatch. Costs associated with Bill C-377 One of several concerns that the IBEW has with this bill is the cost to implement, maintain, and the amount of work that our Local Unions will bear in order to comply with this legislation. Several organizations such as the Canadian Office of the Building and Construction Trades Department and the Canadian Labour Congress submissions go into greater detail surrounding items such as cost for the government (taxpayer) to design, implement, maintain, and police this bill, as well as the cost to the union (dues paying members) for them to comply with the legislation. We would recommend that the Senate Standing Committee on Banking, Trade, and Commerce review those submissions regarding cost factors.

The IBEW feels that union members will be paying twice if this bill becomes law. The Canadian tax payer will be paying the CRA to design, implement, maintain, and police, and union members, who are also Canadian tax payers, will likely see an increase in dues or decrease in benefits or services in order to cover the cost for unions to comply with the legislation.

Point of Clarification from BANC hearings

During the BANC hearings on Wednesday May 29th, 2013 President of Merit Canada, Terrance Oakey stated during his questioning that

“Mr. Blakely said that you know, this ah this um legislation is so Merit members can go on a fishing expedition yet all of this information, if I really wanted to go on a fishing expedition, I would just go to the world wide web because its already disclosed, so, you know under the United States, you know, because he is an affiliated union with ah in the United States so if there were any kind of competitive advantage it would have already been disclosed in the United States.”

The information provided by Mr. Oakey is factually incorrect and should be noted by members of the committee. We would like to inform you exactly who reports in the United States. Due to the fact that the IBEW is an International Union, any employee who is paid through our IBEW headquarters in Washington is subject to disclosure in the United States, even if we are Canadian members and working in Canada. The IBEW has over 65,000 members in Canada in over 85 Local Unions. None of those 85 Local Unions report under the United States LMRDA. In Canada the IBEW has twenty-five (25) members who are considered employee’s of our IBEW First District (Canadian) office. The IBEW has eleven districts and Canada represents district one or first district. The 25 IBEW members that work in Canada for the First District are

The International Brotherhood of Electrical Workers, First District (Canada) Page 12 all paid from our headquarters in Washington D.C. and therefore are subject to LMRDA filing and LM2 reporting requirements in the United States.

Therefore Mr. Oakey’s statement about Merit Canada or their members going on a fishing expedition for information would be highly inaccurate. They would be able to access information from our Washington office on those twenty-five (25) members, or any IBEW Local Union in the United States, but they would NOT be able to access any information on our eighty-five (85) Local Unions in Canada since they are not required to file in the US. However, Merit Canada, their members, and anyone else would be able to access all the information required in Bill C-377 on all of our eighty-five (85) Local Unions here in Canada should the bill become law.

Closing

The IBEW and our members are very concerned about this bill and ask that the Senate Standing Committee of Banking, Trade, and Commerce seriously consider the ramifications of this bill and the “Pandora’s box” that it could open upon passage.

Senators of all stripes, Liberals, Conservatives, Progressive Conservatives, and Independents have spoken out against the Bill during second reading. We have provided a couple of quotes that we feel are important and in some ways reflect how the IBEW feels about the bill.

Hon. Senator Hugh Segal stated:

“I want to point out that, while transparency is a compelling public good, applying it in a discriminatory way is harmful and divisive.”

“..this bill is about a nanny state; it has an anti-labour bias running rampant; and it diminishes the imperative of free speech, freedom of assembly and free collective bargaining.”

Hon. Senator James Cowan stated:

“There is no public policy that is served by this kind of disclosure. The only purpose, as I said, is to bury labour organizations in administrative work, preventing them from doing their real work, and presumably setting the table so the government can later turn to the union members and say, "See? Your union is not working for you; they are spending all their time on administration."

“Of course, there are the unintended consequences, as businesses can scour the filings and find out what their competitors are charging labour organizations for services — for neighbours and others to find out what some neighbour, friend or relative is being paid.”

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“Is this what our tax code should be used for? Is this the kind of law we want to be passing?”

The IBEW believes that this is not a National Public Policy concern, just a concern by a competitor who wishes to use the government to advance their business interests while at the same time bury unions in red- tape and onerous public reporting for anyone to scrutinize the information required by this bill.

The IBEW has strict financial reporting requirements that must be adhered to in our Constitution, along with the numerous labour laws that require financial disclosure in eight jurisdictions across Canada.

The IBEW asks that the Committee outright reject this seriously flawed Bill for what the bill seeks to do to labour organizations such as the IBEW. We strongly believe that this bill is beyond amendments and should be thrown out.

Proponents of this bill continue to cite a Nanos Poll for LabourWatch from 2011, while opponents of the Bill such as the Canadian Labour Congress and The Canadian Office of the Building & Construction Trades Department have conducted polls on the issue as well. While we are not stating that any of the above mentioned polls are inaccurate, we would like to point out that there were several polls recently that did not reflect the final outcome.

Let’s start with polls that showed the BC NDP party winning a majority government for the 12 months prior to their May 14th Provincial election, or the polls that showed the Wildrose Party would win a majority government in Alberta’s previous provincial election, and of course the large lead that and his Progressive Conservatives had and were favored to form a majority government in Ontario in October 2011 & was even favoured in 2014 until his policy announcement of cutting 100,000 jobs. None of those polls were accurate. So we would like to ask you, the House of Sober Second Thought, to take all three polls for LabourWatch, the Canadian Labour Congress, and the Canadian Building Trades department and toss them to the curb along with this bill.

The International Brotherhood of Electrical Workers would like to thank for your interest in our submission, should your Committee have any questions, or require further information please do not hesitate to contact us.

Respectfully submitted

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