If two or more entities are deemed to be "related" under the ESA, then the number of employees working for both entities in Ontario would be counted in the aggregate. For example if entity A has 10 employees, and entity B has 17 employees, and A and B are deemed to be related, then both A and B would be required to develop a Right to Disconnect Policy because in the aggregate they together employ 27 employees. Whether the parent / subsidiary would be considered to be related under the ESA is a complex legal analysis for which legal advice ought to be sought.