On June 1, 2017, the Supreme Court of Canada refused to hear the appeal of Mr. Styles’ claim for the value of his long term incentive plan (LTIP) bonus which had not vested at the time of his dismissal. In light of the Supreme Court’s decision, our own Court of Appeal decision (Styles v Alberta Investment Management Corporation, 2017 ABCA 1) remains an authority on the entitlements of employees to long term incentive plans upon termination.Mr. Styles’ employment agreement with AIMCo clearly set out, in a number of clauses, that he had to be actively employed with AIMCo to be entitled to his long term incentive plan bonus. In the trial decision, the Court held that AIMCo had unfairly exercised its discretion in firing Mr. Styles before his long term incentive bonus vested and deprived him of his entitlement to that bonus. The bonus associated with Mr. Styles’ LTIP did not vest until four years after the date of his termination, but the trial judge awarded him the full entitlement. This element, by itself, was concerning because most prior decisions awarded bonuses only if the entitlement vested within the applicable period of notice of termination awarded by the Court. In addition, the trial judge held that AIMCo had breached its employment contract with Styles by terminating him early and preventing the vesting of his LTIP bonus.On appeal, the Alberta Court of Appeal held that it was clear and unambiguous from a plain reading of Mr. Styles’ employment agreement, and the LTIP clauses in particular, that Mr. Styles’ entitlement to any bonus under the plan would not vest unless he was actively employed with AIMCo as of a certain date. Mr. Styles testified that he fully understood what he had bargained for in his employment contract, including the LTIP clauses. The Court held it was his responsibility to have negotiated for vesting of the LTIP bonus in the event of his early termination.The Alberta Court of Appeal’s analysis of the case clarifies the law surrounding plain language interpretation of employment agreements as well as the basic principle that termination of an employment relationship is not, in and of itself, a breach of that contract. If an employment agreement clearly states that active employment is required for bonus entitlements to vest, then that plain language reading will apply.The key takeaway is that employers must ensure their employment agreements include a clear requirement that an employee be actively employed at the time of vesting to be entitled to any bonuses. In addition, employment agreements should be specific in setting out that employees are not entitled to bonuses if those bonuses vest within the notice period of termination.