What are the fiduciary duties of an employer in an employment relationship?

The defendants suggest that fiduciary duties in an employment relationship will only be imposed in cases where the employer experiences “extraordinary vulnerability” at the hands of its employee. In my view, there is simply no concept at law of extraordinary vulnerability. In Frame v. Smith, supra, and other related decisions speak of the beneficiary being “peculiarly vulnerable” to or at the mercy of the fiduciary. The phrase “particularly vulnerable” suggests that the beneficiary is uniquely vulnerable to damages if the fiduciary was to breach the duties owed to the beneficiary.