Dollarama discloses that the majority of its warehouse and distribution centre staffing needs are outsourced to “well-established third-party agencies”. Dollarama does not serve as employer to such staff, which are instead employees of the third-party staffing agencies. Dollarama states that it is not responsible for hiring or training such workers. In its June 2021 ESG Report, Dollarama describes the need for relying on third-party agencies for its warehouse and distribution centre staffing needs: The use of such agencies is integral to our business model in order to continuously maintain the significant staffing requirements of these un-automated operations, needs which fluctuate throughout the year based on sales volumes, and to fulfill positions that are subject to regular turnover due to the large number of entry-level positions. Employment Practices of Leading Canadian Retailers Leading Canadian retailers Loblaw, Metro and Canadian Tire clearly face the same fluctuating seasonal needs, yet none of them disclose using third-party staffing agencies to staff their warehouses and distribution centres. In fact, certain warehouse/distribution centres for Loblaw and Metro are unionized. Further, each of Loblaw, Metro and Canadian Tire have vendor/supplier codes of conduct that require that suppliers allow their employees the lawful right to free association / collective bargaining. Dollarama’s ESG Report addresses Dollarama’s focus on safeguarding human rights in its supply chain, and it states that Dollarama launched an enhanced vendor/supplier code of conduct in June 2021 which draws upon the UN Guiding Principles on Business and Human Rights (UNGPs). However, and interestingly, Dollarama’s enhanced vendor/supplier code of conduct does not require suppliers to respect their employees’ right to free association / collective bargaining. Human Rights Risk and Third-Party Staffing Agencies The leading centre of expertise on the UNGPs, Shift, together with the Institute for Human Rights and Business (IHRB), developed a guide for the implementation of the UNGPs by staffing agencies. The guide states that staffing agency workers may have heightened vulnerability to adverse human rights impacts, particularly where “[t]hey cannot join a trade union at the user enterprise, and lack equivalent representation and collective bargaining ability in their relationship with the E&R [employment & recruitment] agency.” The guide states that this “may lead to agency workers sometimes receiving lower wages and benefits than workers hired directly for the same jobs, non-payment of benefits, discrimination or the effective denial of freedom of association and collective bargaining rights.” Furthermore, a 2016 report from the Director of Public Health for Montréal notes the risk of occupational injury is between “high” and “extreme” for temporary agency workers. Agency workers account for a higher proportion of injuries, and their occupational vulnerability causes them to hesitate to report occupational injuries and file for compensation.