Confédération des syndicats nationaux with support from Oxfam and Amazon Canada Fulfillment Services ULC: Final Statement

Summary

1. On November 24, 2025, the Canadian National Contact Point (“NCP”) received a request for review submitted by the Confédération des syndicats nationaux (“CSN”), with the support of Oxfam, (“the Notifier”) concerning the activities of Amazon Canada Fulfillment Services ULC (“the Respondent”).
2. The submission raised concerns regarding the Respondent’s observance of the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (“the Guidelines”), in particular Chapters II (General Policies), IV (Human Rights), and V (Employment and Industrial Relations), in relation to the closure of the Respondent’s facilities in Québec.
3. As part of the NCP’s assessment, Canada’s NCP secretariat engaged separately with both parties. The Respondent also provided a written response to the complaint, which was shared with the Notifier.
4. In assessing the submission, the NCP considered the issues raised in light of the expectations set out in the Guidelines, including in relation to freedom of association, collective bargaining, non-retaliation, and human rights due diligence. The NCP also took into account that the factual circumstances underlying these issues are currently under active examination in proceedings before Québec labour and judicial authorities.
5. In this context, and noting the Notifiers’ interest in forward-looking outcomes, the NCP has determined that it can best contribute to the objectives of the Guidelines by proceeding directly to a Final Statement with recommendations to the Respondent, rather than offering good offices, in order to support alignment with the Guidelines while avoiding duplication of, or interference with, the ongoing judicial proceedings in Quebec.
6. Both parties were provided an opportunity to review and provide comments on the NCP’s final assessment prior to its finalization and publication.
7. This assessment does not represent a determination as to whether the Respondent has acted consistently with the Guidelines. It should not be seen as validating to any degree – one way or the other – claims made by either of the parties.

1. Substance of the Specific Instance

1.1 Parties

8. The main Notifier, CSN, is a Québec-based trade union confederation constituted under Québec law, with its headquarters in Montréal. It represents approximately 330,000 workers across more than 1,600 affiliated unions. The CSN has led a campaign to unionize Amazon facilities in Québec since 2022 and was supported in this effort by the Fédération du commerce inc., an affiliated organization providing expertise in labour relations and collective bargaining.
9. The submission also relates to several CSN-affiliated unions, including the Syndicat des travailleuses et travailleurs d’Amazon Laval – CSN, the Syndicat des travailleuses et travailleurs d’Amazon Montréal – CSN, and the Syndicat des travailleuses et travailleurs d’Amazon Saint-Hubert – CSN, which represented workers in Amazon’s former warehouse and logistics operations in Québec. The Laval union obtained certification on May 10, 2024 to represent employees at the DXT4 facility, an Amazon fulfillment centre that was located in Laval, Québec.
10. The submission is supported by Oxfam, a confederation of independent affiliates, including organizations based in Canada and the United States. Oxfam engages in advocacy on economic justice, labour rights, and responsible business conduct, including encouraging companies and governments to respect workers’ rights. Oxfam United States has also shared its position with Amazon.com, Inc in recent years on issues related to “worker voice” (a term used by Oxfam to describe workers’ ability to raise workplace concerns without fear of retaliation), collective bargaining, working conditions, and broader human rights impacts.
11. The Respondent, Amazon Canada Fulfillment Services ULC (“Amazon Canada”), is a corporation incorporated under the Canada Business Corporations Act and continued under the laws of British Columbia, with its registered office in Vancouver. It operates as part of the global Amazon group, whose ultimate parent company, Amazon.com, Inc. (“Amazon”), is a publicly traded multinational enterprise headquartered in Seattle, United States.
12. Amazon Canada employs approximately 46,000 employees in Canada as of early 2025, including more than 1,900 employees in Québec. At the time of the events described, Amazon Canada operated seven facilities in Québec. These facilities were located across the Greater Montréal region, including sites in Montréal (Lachine), Laval (North Shore), Longueuil/Saint-Hubert (South Shore), and Coteau-du-Lac in western Québec. They included the YUL2 fulfillment centre in Lachine (Montréal); the YUL5 sortation centre and the HYU1 distribution centre for extra large items in Saint-Hubert (Longueuil); the YUL9 sortation centre in Coteau-du-Lac; the DXT4 and DXT5 delivery stations in Laval; and the DXT6 delivery station in Lachine (Montréal).

1.2 Perspectives of the Notifiers

13. The Notifiers alleged that the Respondent engaged in conduct inconsistent with the Guidelines, in particular Chapter V (Employment and Industrial Relations), Chapter II (General Policies), and Chapter IV (Human Rights).
14. The Notifiers submitted that the Respondent interfered with workers’ rights to establish and join trade unions and to engage in collective bargaining (Chapter V, paras. 1(a), 1(b), and 8), including by failing to recognize and engage constructively with workers’ representatives and to promote consultation and co-operation (Chapter V, paras. 2(a), 2(b), and 4).
15. The Notifiers further alleged that the Respondent engaged in reprisals against workers in connection with union activities (Chapter II, para. A.9), including through the closure of facilities and termination of employment following union certification. They also raised concerns that the Respondent failed to respect human rights (Chapter II, para. A.2; Chapter IV, para. 1), and did not adequately identify, prevent, mitigate, or address adverse human rights impacts associated with these actions (Chapter II, para. A.12; Chapter IV, paras. 2, 3, and 6), including through insufficient human rights due diligence.
16. The Notifiers also alleged that the Respondent engaged in conduct inconsistent with the expectation to refrain from threatening to close or transfer operations in order to influence collective bargaining or the exercise of workers’ rights (Chapter V, para. 7).
17. The Notifiers sought outcomes including the reinstatement of affected workers, the reinstatement of commercial relationships with delivery service partners and their driver associates, recognition of the union at the DXT4 facility, and compensation for affected workers, including lost wages, benefits, and damages. They also requested forward-looking commitments from the Respondent, including respect for workers’ rights to freedom of association and collective bargaining (Chapter V), the adoption of non-retaliation measures (Chapter II), and the strengthening of human rights due diligence processes (Chapter IV), with a view to ensuring alignment with the Guidelines.

1.3 Perspectives of the Respondent

18. The Respondent disputed the allegations raised by the Notifiers and maintained that its conduct is consistent with the Guidelines, including Chapter II (General Policies), Chapter IV (Human Rights), and Chapter V (Employment and Industrial Relations).
19. The Respondent submitted that the allegations of union suppression, refusal to bargain in good faith, and retaliation are misleading and unsupported by evidence. It stated that its communications with employees in the context of unionization efforts were lawful and intended to provide information about employees’ rights, and not to interfere with freedom of association (Chapter V, para. 1(a)) or to intimidate workers. The Respondent noted that the Québec Administrative Labour Tribunal, in its review of these communications, concluded that the Respondent’s messages to employees were not threatening and did not constitute any form of intimidation.
20. The Respondent further maintained that it engaged in collective bargaining in good faith, including through numerous negotiation sessions held between July 2024 and January 2025. The Respondent maintained that it never refused to engage in arbitration nor otherwise undermined the bargaining process (Chapter V, paras. 1(b) and 8). It submits that its decision to challenge aspects of Québec’s labour certification regime did not impede its participation in negotiations, and that continuing to participate actively in collective bargaining while exercising its legal rights demonstrates its commitment to good-faith engagement.
21. With respect to the closure of its Québec facilities and associated terminations, the Respondent stated that these decisions were based on legitimate business considerations, including the unexpected suspension of operations at one of its facilities and the subsequent identification of alternative service delivery models that would allow it to provide a similar level of service at lower cost. It rejected the characterization of these actions as retaliatory or as interference with workers’ rights (Chapter II, para. A.9; Chapter V, para. 7) and maintained that such decisions fall within its discretion as a business operator acting in the normal course of business.
22. The Respondent also emphasized that all of the issues raised in the submission are the subject of multiple ongoing legal proceedings before Québec administrative and judicial bodies, where the parties have the full opportunity to conduct discoveries, submit evidence, and present their arguments. The Respondent submitted that the request represents an attempt to bypass these established legal proceedings, the NCP process should not be used to circumvent these proceedings, and has indicated that consideration of the request should be suspended pending the resolution in the ongoing parallel proceedings.

2. Initial Assessment

23. The NCP’s initial assessment was based on the information provided by both parties, as well as publicly available information. The assessment considers whether the issues raised are bona fide and relevant to the implementation of the Guidelines, taking into account the identity of the parties, the materiality and substantiation of the issues, the link between the enterprise’s activities and the issues raised, the relevance of applicable law and procedures, the treatment of similar issues in other proceedings, and whether further consideration would contribute to the purposes and effectiveness of the Guidelines.
24. This assessment does not represent a determination as to whether the Respondent has acted consistently with the Guidelines. It should not be seen as validating to any degree – one way or the other – claims made by either the Notifiers or the Respondent.

2.1 Identity of the parties concerned

25. The Notifiers, CSN, represent workers directly affected by the issues raised in this submission and have been actively involved in organizing employees at certain of the Respondent’s facilities in Québec. The submission is supported by Oxfam, an organization with experience in labour rights and responsible business conduct. The NCP considers that the Notifiers have a sufficient interest in the matter.

2.2 Materiality and substantiation

26. The NCP has considered whether the issues raised are material to the Guidelines and sufficiently substantiated to warrant further consideration. The submission raises concerns related to freedom of association, collective bargaining, and the management of labour-related impacts in the context of the Respondent’s operational decisions. These issues are directly relevant to Chapters II (General Policies), IV (Human Rights), and V (Employment and Industrial Relations) of the Guidelines.
27. The submission provides a detailed account of the factual context, including the certification of a union at the Respondent’s Laval facility, subsequent labour relations developments, and the closure of facilities in Québec affecting a significant number of workers. The Respondent disputes the characterization of these events and has provided its own account, including the rationale for its decisions and its approach to labour relations.
28. At this stage, the NCP does not assess the merits of these differing accounts and has not reached any conclusions regarding the parties’ respective claims. However, the NCP considers that the issues raised are sufficiently substantiated for the purposes of an assessment and are material to the Guidelines.
29. The NCP has considered all issues raised in the submission and distinguishes between those that are appropriate for further consideration under the Guidelines and those that fall outside its mandate.
30. The NCP considers that the issues appropriate for further consideration concern the Respondent’s approach to workers’ rights to freedom of association, collective bargaining, and non-retaliation. These issues are relevant to Chapter V (Employment and Industrial Relations), including paragraphs 1(a), 1(b), 2(a), 2(b), 4, 7 and 8, as well as Chapter II (General Policies), including paragraph A.9.
31. The NCP also considers relevant the Respondent’s approach to respecting human rights and to identifying, preventing, and addressing potential human rights impacts, including those associated with significant operational decisions affecting workers. These issues are relevant to Chapter II (General Policies), including paragraph A.2 and A.12, and Chapter IV (Human Rights), including paragraphs 1–3 and 6.
32. The NCP has not accepted for further consideration those aspects of the submission that seek specific remedies, including the reinstatement of workers, the restoration of commercial relationships with delivery service partners and their driver associates, and the awarding of compensation and damages, as these fall outside the NCP’s role as a non-judicial grievance mechanism.

2.4 Link between the enterprise’s activities and the issues raised

33. The issues raised relate directly to the Respondent’s operations in Québec, including its labour relations practices and operational decisions affecting its workforce. The NCP considers that there is a clear link between the Respondent’s activities and the issues identified in the submission.

2.5 Relevance of applicable law and parallel proceedings

34. The NCP notes that the factual circumstances underlying the issues raised in the submission are largely the subject of ongoing proceedings before the Québec Administrative Labour Tribunal (ALT). These proceedings address the application of Québec labour law, including allegations concerning interference with union activities, collective bargaining processes, and claims for remedies such as reinstatement and compensation.
35. The Guidelines provide a distinct, non-judicial mechanism focused on responsible business conduct. In accordance with the Procedural Guidance for NCPs (Annex I, Commentary), the existence of parallel proceedings does not preclude consideration of issues under the Guidelines; however, NCPs are expected to assess whether their involvement would contribute to the purposes and effectiveness of the Guidelines without creating undue prejudice to the parties or interfering with those proceedings.
36. In this context, the NCP has assessed whether its review could contribute to the purposes and effectiveness of the Guidelines while avoiding duplication of, or interference with, matters before the ALT. The NCP considers that it can do so by focusing on the Respondent’s policies and practices in light of the expectations set out in the Guidelines, rather than examining or making findings in relation to the factual circumstances under consideration in those proceedings.
37. Accordingly, the NCP has limited its review to forward-looking considerations relating to the Respondent’s approach to freedom of association, collective bargaining, non-retaliation, and human rights due diligence. This approach allows the NCP to contribute to the objectives of the Guidelines while avoiding duplication of, or interference with, the ongoing proceedings before the ALT.

2.6 Contribution to the purposes and effectiveness of the Guidelines

38. The NCP considers that further examination of the Respondent’s approach to freedom of association, collective bargaining, non-retaliation and human rights due diligence has the potential to contribute to the purposes and effectiveness of the Guidelines.

3. Conclusion

39. The NCP considers that the issues raised in the submission are relevant to the Guidelines, including with respect to workers’ rights to freedom of association and collective bargaining, non-retaliation and the Respondent’s approach to respecting human rights and conducting human rights due diligence, as reflected in Chapters V (paras. 1(a), 1(b), 2(a), 2(b), 4, 7 and 8), II (paras. A.2 and A.9) and IV (paras. 1–3 and 6), as cited in the complaint. This assessment of relevance is made without examining or making findings in relation to the specific factual circumstances described in the submission.
40. However, the NCP notes that the factual circumstances underlying the issues raised in the submission are currently under active examination in proceedings before the Québec ALT. These proceedings address key elements of the dispute - including allegations concerning labour relations practices, the circumstances surrounding facility closures, and requests for remedies such as reinstatement and compensation - and constitute the primary forum for the determination of facts, legal liability, and appropriate remedies under Québec labour law. The NCP also notes that these proceedings are ongoing and evolving, and that their outcome remains uncertain.
41. In light of this, the NCP has carefully considered whether the provision of good offices would add value in advancing the resolution of the issues raised, while avoiding overlap with or interference in matters properly before a judicial body. The NCP considers that facilitating dialogue between the parties at this stage would likely involve issues that are central to the ongoing proceedings, including questions relating to the motivations for operational decisions and the characterization of the Respondent’s conduct. Engaging on these matters through good offices could therefore risk duplicating or prejudicing issues under active adjudication, or placing the parties in a position where participation in the NCP process might affect, or be perceived to affect, their respective legal positions.
42. At the same time, the NCP notes that the submission raises broader, forward-looking considerations regarding the Respondent’s policies and practices in relation to workers’ rights and human rights due diligence, and that the Notifiers have expressed an interest in outcomes in these areas. The NCP considers that these systemic issues are distinct from the questions of legal liability and remedy currently before the ALT and fall squarely within the NCP’s mandate to promote the effective implementation of the Guidelines.
43. In this context, the NCP considers that the issuance of a Final Statement with targeted, forward-looking recommendations is the most appropriate and effective means of contributing to the objectives of the Guidelines. This approach enables the NCP to provide clear and practical guidance to the Respondent on how its policies and practices may be strengthened in line with the expectations set out in the Guidelines, while supporting meaningful forward-looking outcomes and maintaining appropriate deference to the role of domestic adjudicative bodies. It also avoids any risk of duplication of, or interference with, the ongoing proceedings and ensures that the NCP’s intervention remains constructive and consistent with its role as a non-judicial grievance mechanism.
44. The NCP reiterates that the issuance of recommendations does not represent a determination as to whether the Respondent has acted consistently with the Guidelines. It should not be seen as validating to any degree – one way or the other – claims made by either of the parties.

4. Recommendations to the Respondent

45. The NCP notes that the Respondent’s parent company, Amazon, has established Global Human Rights Principles (“GHRP”), which are publicly available on its website and set out a policy commitment to respect internationally recognized human rights, including labour rights, and reference alignment with the United Nations Guiding Principles on Business and Human Rights.^{Footnote 1} Amazon’s GHRPs address a range of human rights issues, including freedom of association, non-discrimination, and working conditions. They also outline Amazon’s approach to human rights due diligence, including processes to identify, prevent, and mitigate potential adverse impacts, as well as stakeholder engagement and remediation mechanisms.
46. The NCP recognizes that multinational enterprises may adopt global policies, such as Amazon’s GHRPs, to address labour rights, human rights, and human rights due diligence. The Guidelines provide that such commitments should be integrated into policies and management systems and reflected in operational decision-making, including through risk-based due diligence processes that are ongoing and proportionate to the enterprise’s operations and potential impacts (Chapter II, paras. A.2 and A.12; Chapter IV, paras. 2 and 5).
47. In this context, the NCP notes that the effective implementation of such enterprise-level commitments depends on how they are operationalized across the enterprise, including its subsidiaries and operations, such as the Respondent’s practices in Canada. This includes, in particular, taking into account the legal and operational environment in Canada, identifying and assessing risks at the local level, adapting relevant policies and management systems as appropriate, and engaging meaningfully with workers and their representatives and other stakeholders who may be affected by the Respondent’s activities (Chapter II, para. A.14; Chapter IV, para. 5).
48. The following recommendations are forward-looking and are intended to support the Respondent in strengthening alignment with the Guidelines in its operations in Canada. In this regard, the NCP invites the Respondent to consider the following areas.
49. On freedom of association and collective bargaining (Chapter V, paras. 1(a), 1(b), 2(a), 2(b), 4 and 8), the NCP invites the Respondent to consider:
    • further clarifying and communicating its commitment, in the Canadian context, to respect workers’ rights to establish or join trade unions and to engage in collective bargaining with duly recognized unions;
    • ensuring that internal procedures and training for managers and supervisors support conduct aligned with expectations to promote consultation, co-operation, and constructive engagement;
    • strengthening processes that enable regular, good-faith engagement with workers and their representatives, including recognized unions, in line with expectations under the Guidelines.
50. On non-retaliation and responsible conduct in operational decision-making (Chapter II, para. A.9; Chapter V, para. 7), the NCP invites the Respondent to consider:
    • reinforcing safeguards to prevent retaliation against workers engaging in union or other protected labour activities;
    • incorporating processes to assess potential impacts of significant operational decisions on workers’ rights, including risks related to freedom of association and collective bargaining;
51. On human rights due diligence and remediation (Chapter II, para. A.2 and A.12; Chapter IV, paras. 1–3, 5 and 6), the NCP invites the Respondent to consider:
    • strengthening engagement with affected stakeholders, including workers and their representatives, as part of ongoing due diligence processes;
    • enhancing access to grievance and remediation mechanisms, and, where relevant, providing for or co-operating in remediation;
    • improving transparency, including, where appropriate, reporting on approaches to identifying and addressing labour-related human rights risks.
52. These actions are intended to operationalize the expectations set out in the Guidelines in a manner that is practical and adapted to the Respondent’s Canadian operations.
53. The NCP will follow up on its recommendations in accordance with its usual practice. The NCP may request that the Respondent provide an update on how the recommendations have been considered within a reasonable period of time.

Timeline

November 24, 2025 – Request for review submitted by the Notifiers and received by the NCP

December 15, 2025 – Complaint shared with the Respondent; response requested by end of January 2026

December 16, 2025 – Notifiers’ legal counsel contacted the NCP and identified themselves as the point of contact

January 21, 2026 – NCP held a call with the Notifiers to discuss the request for review

February 6, 2026 – Respondent’s legal counsel requested an extension to submit the response

February 27, 2026 – Respondent’s response to the complaint received by the NCP

March 24, 2026 – Respondent agreed to share its response with the Notifiers

March 25, 2026 – Respondent’s response shared with the Notifiers

April 27, 2026 – Draft Final Statement shared with the Parties