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An $80-million proposed class action lawsuit has been filed against RBC Life Insurance Company alleging the firm short-changed commissioned employees on vacation and public holiday pay, and failed to pay them for overtime.

A statement of claim detailing the allegations was filed by Toronto-based law firm Monkhouse Law on Tuesday. In April, the same law firm launched a proposed class action against RBC Insurance Agency Ltd. and Aviva General Insurance Company, alleging they also short-changed commissioned employees in calculating their vacation and public holiday pay.

The statement of claim alleges that Maureen Barrett, a former commissioned employee of RBC Life Insurance, had her vacation pay and statutory holiday pay calculated based solely on her base salary, without factoring in her commissions, in contravention of Ontario’s Employment Standards Act. It also alleges that Barrett regularly worked in excess of 44 hours per week without receiving overtime pay.

Barrett seeks to be a representative plaintiff in the proposed class action.

Monkhouse Law seeks to have the time period for the class action, which has not been certified, run from 1999, when RBC Life Insurance was founded.