 Finland, Germany, Austria, Switzerland, Hungary and Bulgaria are the only countries in Europe where employees can legally claim an employment reference, including the right to a correct, unambiguous and benevolent appraisal.While there is no common law duty to provide a reference, the Supreme Court of Canada has held that a refusal to do so may constitute "conduct that is unfair or is in bad faith" with respect to a wrongful dismissal, and thus "indicative of the type of conduct that ought to merit compensation by way of an addition to the notice period.