In Guerin v. The Queen, 1984 CanLII 25 (SCC),  2 S.C.R. 335 at 384, Dickson J. (as he then was) confirmed that fiduciary relationships may be created by contract: [W]here by statute, agreement, or perhaps by unilateral undertaking, one party has an obligation to act for the benefit of another, and that obligation carries with it a discretionary power, the party thus empowered becomes a fiduciary. Equity will then supervise the relationship by holding him to the fiduciary's strict standard of conduct.
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