Indirect Solicitation can be a breach of Fiduciary’s Obligations

January 30, 2013
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1,540 comments

An Alberta Court of Appeal decision has confirmed the obligations of fiduciary employees who leave their former employer and solicit their clients – even indirectly – away. Richard Evans, a sport agent who worked for 6 years with The Sports Corporation (“TSC”) signed a non-solicitation agreement which was ultimately determined to be unenforceable by the Court of Appeal.

Notwithstanding that unenforceable agreement, Evans was ordered to pay his former employer over $200,000 in damages for breach of fiduciary duty when he struck out on his own and diverted some former players from TSC. Though he had not directly approached the players, he was just as liable for the indirect solicitation as if he had done it himself, which was a breach of his fiduciary duty to TSC. The court noted that in his role at TSC he was the face and voice of TSC to his overseas clients and their players, leaving TSC vulnerable should he have left the company.

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