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13. On or around March 24, 2021, the Company sent associates who had not yet provided
their vaccination status a letter reminding them that Compass strongly encouraged
vaccination. In addition, the Company stated the following:
Our clients may not permit unvaccinated associates to work if there is an outbreak
in the home. This could result in you being removed from the unit and placed on
an unpaid Leave of Absence for the duration of the outbreak.
The letter also requested that employees provide a response regarding their COVID-19
vaccination status by March 31, 2021 (Tab 7).
14. On June 9, 2021, Revera advised the Company of its COVID-19 immunization policy,
procedure, and education policy (Tab 8). On June 24, 2021, the Company advised all
management team members working in long-term care homes about the application of the
Ontario Minister’s Directive on the long-term care home COVID-19 immunization policy.
As of July 1, 2021, all Compass managers working in long-term care in Ontario would be
required to enforce the requirements of their long-term care client’s COVID-19
immunization policy and the provisions of the Minister’s Directive (Tab 9). Compass set
out FAQs regarding the Ontario Minister’s Directive on Long-Term Care Home COVID-19
Immunization Policy, including information on proof of vaccination (Tab 10).
15. On July 1, 2021, the Minister of Long-Term Care issued a Minister’s Directive: Long-term
care home COVID-19 immunization policy setting out requirements for the establishment,
implementation, and reporting of a COVID-19 immunization policy for long-term care
establishments. The Directive applied to all staff, student placements, and volunteers,
regardless of the frequency or duration of any period of time they attended the long-term
care home. All individuals subject to the COVID-19 immunization policy were required to
provide long-term care homes (i) proof of COVID-19 vaccination of each dose of an
approved COVID-19 vaccine; (ii) written proof of a medical reason that the individual could
not be vaccinated against COVID-19, including the effective time period for the medical
reason; or (iii) proof that the individual completed an educational program approved by the
long-term care home about the benefits of vaccination and the risks of not being vaccinated
16. On August 26, 2021, a coalition of seniors’ living operators, including the Company’s
clients, announced that they were making COVID-19 vaccination mandatory for long-term
care and retirement home staff and third parties (Tab 12).
17. On the same day, Revera, one of the Company’s clients, published a question and answer
page related to its mandatory staff vaccination policy. Effective October 12, 2021, Revera
would require all staff to be fully vaccinated for COVID-19 and provide proof of vaccination.
Refusal to adhere to any measures outlined on the page would result in being placed on
an unpaid leave. Third party agency workers would not be given access to Revera’s sites
18. On September 2, 2021, the Minister of Long-Term Care issued Minister’s Directive: Long-
term care home COVID-19 immunization policy mandating that all Ontario long-term care
homes adopt and implement written COVID-19 immunization policies, which required all
staff, students, and volunteers in long-term care homes to provide proof of full vaccination,
written proof of a medical exemption, or proof of completion of an educational session
regarding the benefits of vaccination (Tab 14).