Report on the 2022 Survey of Public Office Holders subject to the Conflict of Interest Act

​​​​​​​​​​​​​​​​Overview

Background and purpose

The purpose of the 2022 Survey of Public Office Holders was to gather baseline metrics and general insights into how the Office of the Conflict of Interest and Ethics Commissioner (OCIEC) can improve how it communicates and engages with public office holders subject to the Conflict of Interest Act.

Research objectives

To obtain baseline measures of:

• Knowledge of the OCIEC's mandate/purpose

• Interaction frequency with the OCIEC

• Perceived value of the OCIEC

• Perceived level of the OCIEC's trustworthiness

• Perceived level of the OCIEC's credibility

• Perceived level of the OCIEC's timeliness/proactivity

• Satisfaction with most recent OCIEC interaction ​
  

To obtain feedback regarding:

• Preferred OCIEC communication vehicles/channels

• General interest in receiving information from the OCIEC

• Preferred frequency of OCIEC communication

• Interest in OCIEC training opportunities    

• Preferred OCIEC training format

• Preferred OCIEC training frequency

• Ways in which the OCIEC can improve to better serve its stakeholders

This survey research was designed to align with the OCIEC's 2021-2024 Strategic Plan, specifically, Key Focus Area #1, Stakeholder Communications & Engagement. The goal for this focus area is to “increase trust in, and credibility of the OCIEC with key stakeholders so that they become stronger allies in the delivery of the mandate of the OCIEC and can effectively manage conflict of interest issues." 

Methodology

• ​​The survey was developed, tested, and deployed on the NOVI survey platform.

• A total of 1,500 public office holders subject to the Act were invited to take the survey via an email sent directly to them from the Communications, Outreach and Planning division.^[1]
  

• A follow-up reminder email was sent out a few days before the survey was closed.

• The survey was officially open for 11 days, from January 17 to January 28, 2022.

• There were 455 survey respondents resulting in a 30% response rate.

• The average survey completion time was 14 minutes.

• Respondents were able to complete the survey in the official language of their choice (82% opted for English and 18% for French).

Statistical significance

• For questions where everyone responded (n=455) it can be stated that the survey responses represent the views of all public office holders subject to the Act within ±3.8 percentage points 9.5 times out of 10.

• Only a small fraction of respondents skipped entire questions, usually under 10% (less than 45 respondents). In such cases, the survey responses represent the views of all public office holders subject to the Act within ±4.1 percentage points 9.5 times out of 10. ​
  

• The above does not apply to qualitative open-ended responses, follow-up questions to a specific sub-group, and any sections of this report that summarize findings based on a sub-group (e.g., by role). In such cases the sample size (n) and/or a revised margin of error has been provided for reference.

Note to readers

Key findings are presented in the sections that follow. An exact copy of the survey questions and survey instrument used has been provided in Appendix B​.

Key overall takeaways

Positive overall impression of the OCIEC: Most respondents believe that the OCIEC is a credible (80%), impartial (76%), helpful (73%), and trustworthy (81%) organization.

High familiarity with obligations under the Act: The overwhelming majority of respondents (97%) stated they are familiar with their obligations under the Act.

High satisfaction with one-on-one service delivery: Most respondents (84%) that have recently interacted with an OCIEC employee (one-on-one) were satisfied with their experience and thought that the employee was courteous and helpful (91%), provided a timely and accurate response (89%), and provided them with the information they needed (86%).

Strong appreciation of personalized service: Most respondents stated that personal interactions are the top value-add of the OCIEC.

Preference for online training: When asked about preferred training methods, most respondents stated they prefer online training with a live presenter.

The top 3 preferred training topics are (in order):

1. Material changes (assets, activities, etc.)

2. Recusals (private interests)

3. Post-employment ​

Respondent breakdown

Respondents were asked to indicate attributes about their roles for the OCIEC to better understand and analyze the data.

Time as public office holders

The majority of survey respondents (74%) indicated that they have been in their roles for less than five years. ​

Table 1 - Time as public office holder

Role a​s public office holders

The largest proportion of respondents (35%) were full-time tribunal/board/commission members. Approximately 6% of respondents did not place themselves in the role they belong to or did not feel they belong to any of the roles that were provided. Upon review of the comments, the OCIEC was able to categorize the “other" responses into their designated category and reflect them in the analysis.​

Table 2 - Role as public office holder

Familiarity with obligations under the Act

Most respondents (97%) were either somewhat familiar or very familiar with their obligations. Less than 1% stated that they were not at all familiar with their obligations. ​

General findings

Training

Training topics

Most respondents (60%) indicated they are interested in training opportunities from the OCIEC. The training topics of greatest interest are as follows (in order)^[2]:

1. Material change (assets, activities, etc.)

2. Recusals (private interests)

3. Post-employment

4. Gifts

5. Penalties

6. Annual reports

7. Investigation reports

8. Quarterly reports

Respondents were also given an opportunity to state other training topics they would like to see that were not listed in the survey question. After categorizing these open-ended responses, it was determined that most of the specific topics mentioned could effectively be placed into one of the existing top three categories. The only new topics mentioned included cryptocurrency and advice for governor-in-council appointees (only a handful of individuals).

Additional Context

Material Change – The OCIEC website defines material change as “a change to any matter that you were required to include in your Confidential Report and that could affect your obligations under the Act and make it necessary to modify your compliance arrangements." Examples of material change are acquiring assets valued at $10,000 or more, becoming a trustee or a beneficiary of a trust, or opening any type of investment account, among others.

Recusals – The Conflict of Interest Act requires public office holders to recuse themselves from any discussion, decision, debate or vote on any matter in respect of which they would be in a conflict of interest. Respondents might want to know how to determine if a matter presents a conflict of interest, how to properly document recusals, and how to calculate the scope of discussions from which they must recuse themselves.

Post-employment – The Conflict of Interest Act has several provisions relating to post-employment, some limited and some unlimited. For instance, depending on public office holders' former positions, they must wait one or two years before working with a party with which they had “direct and significant dealings" during their time in office. This is commonly known as the “cooling-off" period. This would be a limited provision. However, there are also the following three rules, which apply for life to all former public office holders. They cannot:

• take improper advantage of their previous public office;

• switch sides, meaning act for or on behalf of any person or organization in relation to a specific proceeding, transaction, negotiation or case in which they previously acted for or provided advice to the government;

• provide advice to a client, business associate or employer using information they obtained while in office that is not available to the public.

Gifts – Relates to the following provision in the Conflict of Interest Act: “[Public office holders] must also disclose any gifts or other advantages from any one source, other than relatives and friends, that exceed $200 in value in a 12-month period, within 30 days after acceptance or of the day on which their total value exceeds $200." Gifts can take many forms, for instance meals, tickets to events, reduced rate or free membership to clubs or organizations, and money, among other things.

Penalties – Refers to the punishments that public office holders might receive for violating the rules set out in the Conflict of Interest Act. These penalties can go up to $500 and are published both in the public registry on the OCIEC website and subsequently on Twitter.

Annual reports, investigation reports, and quarterly reports – All of these topics relate to the OCIEC's main communications products. Annual and quarterly reports are published periodically to update the public on the OCIEC's activities. Investigation reports are published after an investigation is completed.

​Training methods

Most respondents (61%) prefer to receive conflict-of-interest-related information proactively rather than searching for it on their own.

The preferred methods of training were stated to be as follows (in order)^[3]:

1. Online educational sessions on a specific topic with live presenters

2. Customized educational group sessions for their organization

3. One-on-one personalized training

4. Self-study with OCIEC-provided materials

5. Online Q&A

Training frequency

Respondents were almost equally divided between preferring to receive training quarterly (31%), annually (32%), or when topical (32%). Very few said monthly (3%) or never (2%).

Commu​​​​nications

Perceived tone of OCIEC mass communication methods

When asked about the tone of OCIEC mass communications, 82% of respondents agreed that the tone was clear, 89% agreed that it was professional and 88% agreed that it was respectful.

Preferred method of OCIEC mass communication

Respondents were asked to rate the existing methods of OCIEC mass communications based on their helpfulness. The percentage in the table below reflects the number of respondents who stated the method in question was either somewhat, very, or extremely helpful.

Table 3 - Most helpful methods of mass communications

As can be​ seen, generic emails from the Commissioner came out on top (76%), whereas using Twitter as a method of OCIEC mass communications was only helpful to about 8% of respondents (21% stated it was not helpful). It should be noted that 71% stated it does not apply to them as they do not use Twitter​.^[4]

Preferred method of OCIEC private (one-on-one communications methods)

Respondents were asked how helpful they found the OCIEC's one-on-one methods of communications. Currently, the OCIEC interacts with public office holders via email or by phone. In-person meetings are infrequent, even during pre-pandemic times. Emails and phone calls are the preferred methods of communications. Over 80% of respondents ranked video conferences and in-person meetings as not applicable.

Table 4 - Preferred private (one-on-one) communications methods

Additional suggested communications methods

Respondents were also asked to comment on other forms of mass and private communication that they would like to see adopted. Only about 5% responded (n=22). The suggested additional methods included text messaging (for its speed and brevity) and LinkedIn.

Perceptions of the OCIEC

General opinion of the OCIEC

Respondents were asked whether they agree with the statement: “My general opinion of OCIEC is positive." 77% of respondents strongly or somewhat agreed and 13% of respondents did not agree or disagree with that statement. The remaining 10% somewhat or strongly disagreed.​

Table 5 - General opinion of the OCIEC

Perception differences (by role)

In the table below, results have been reflected by role to better illustrate how the respondent's role might affect their perception of the OCIEC. For example, part-time members do not have reporting obligations and therefore do not interact as frequently with the OCIEC, which may affect how they perceive it.

In this question, respondents were presented with several statements about the OCIEC and asked to indicate how strongly they agreed or disagreed. The percentages in the table below represent those who answered “strongly agree" or “somewhat agree."^[5]

Table 6 - Perceptions of the OCIEC bas​​ed on respondents’ profiles

While the overall perception of the OCIEC​ is high, the heads of departments as well as part-time members had the highest agreement level with most attributes, specifically, credibility, trustworthiness, and impartiality. The lowest scores came from embassy/consulate staff; however, the sample size from this group was extremely small.

The overall agreement level with the OCIEC being a proactive organization came in at 67%. This was the lowest score out of the provided attributes.

Satisfaction with one-on-one service

Respondents were also asked to think back on their most recent one-on-one interaction with an employee of the OCIEC and indicate how strongly they agreed or disagreed with the provided statements.

Once again, the sentiment tended to be quite positive, with those that agree with each statement seldom falling under 85%. Positive responses tended to once again be weaker among embassy/consulate staff, very likely due to their relative underrepresentation in the survey. Only 3% of respondents were embassy/consulate staff (n=11).​

Table 7 - Perception of most recent one-on-one interaction based on respondents’ profiles

Out of the 10% of people that stated they were dissatisfied with their experience, the top complaint was with the service quality, with some respondents saying that emails or phone calls had gone unanswered and others mentioning insufficient or inconsistent advice. Others, still, had complaints about the rules the OCIEC enforces. As one commenter said: “I was satisfied in that the employee answered my question and was obviously doing her job. I wasn't satisfied with what the law apparently required her to tell me… to complete a 19-page form and provide information that I just confirmed three months ago, because of inflexibility in the legislation."

The OCIEC is looking into the concerns these comments reveal to try and address them as best we can.

Greatest value-add

Respondents were asked to answer an open-ended question as follows: “Which service or program offered by the OCIEC has the greatest value-add in terms of supporting you in meeting your compliance requirements?"

Upon categorizing the 173 responses received, personal interaction with an advisor came out as the greatest value-add of the OCIEC. Respondents appreciated the quick and clear advice they received that related specifically to their situations. The second most cited value-add was the training the OCIEC provides followed by the OCIEC's annual update notices.

The results of this question allow us to understand what we are doing right and gives us ideas for how to adjust our strategy in areas with lower rates of satisfaction.​

Foo​tn​​otes

1 - Public office holders who are Members of the House of Commons and also subject to the Conflict of Interest Code for Members of the House of Commons were not included in the survey.​

​​​2 - Survey respondents were given eight options of topics about which they might receive training. They were asked to rank these topics from 1 to 8, 1 being the topic most interesting to them, and 8 being the least. To make sense of these results, we gathered up all the responses and then generated averages for each item. Consistent with the ranking system, the averages closest to 1 were considered the most interesting topics to respondents, and the closest to 8 were the least interesting.​

3 - Survey respondents were given five options of topics about which they might receive training. They were asked to rank these methods from 1 to 5, 1 being the method most preferred, and 5 being the least. To make sense of these results, we gathered up all the responses and then generated averages for each item. Consistent with the ranking system, the averages closest to 1 were considered the most interesting topics to respondents, and the closest to 5 were the least interesting.

4 - Roughly 30% of the respondents indicated that they rely on Twitter as a source of information about the conflict-of-interest regimes administered by the OCIEC. This is in line with statistics on Canadians' reliance on Twitter as a news source.​

5​ - Between 5% and 25% of the respondents answered “Neither agree nor disagree."​​​​

​Appendix ​​A – Survey results

1. How familiar are you with your obligations under the Conflict of Interest Act?

Question type: Multiple choice

Number of responses: 429

Number of respondents: 455​

OCIEC Stakeholder Sur​vey 2022

1. How familiar are you with your obligations under the Conflict of Interest Act?

• ​Very familiar
  

• Somewhat familiar
  

• Not very familiar
  

• Not at all familiar
  

• The Conflict of Interest Act does not apply to me
  

Do you have any other comments about your most recent private interaction (one-on-one) with the OCIEC?

5. How helpful or unhelpful do you find the following OCIEC mass communication methods?​

8. How helpful or unhelpful do you find the following official OCIEC private (one-on-one) communication methods?​

Do you have any other comments about these private (one-on-one) communication methods that you would like to share?​

9. Please indicate the extent to which you agree or disagree with each of the following statements:​

10. Please rank the following OCIEC related topics in order of importance -- 1 being the most important to you and 8 being the least important.​

• ​​​Not applicable

Responses must be between 1 and 8, inclusive

• Gifts

• Material change (assets, activities, ...)

• Recusals (private interests)

• Penalties

• Post-employment

• Investigation reports

• Annual reports

• Quarterly reports​
  

11. Are there any other topics that you would like the OCIEC to provide more information and/or training on?​

• Yes

• No

If you replied "yes," please specify the topic(s).​

12. Please rank the following OCIEC training delivery formats in order of preference - 1 being the most preferred and 5 being the least preferred​.

• ​​Not applicable

Responses must be between 1 and 5, inclusive

• Online educational session on a specific topic with live presenters

• Self-study with OCIEC-provided materials

• One-on-one personalized training

• Customized educational group session for your organization

• Questions and answers online session

Are there other training delivery formats that you would like us to use?​

13. How often should the OCIEC be offering live educational opportunities?​

• Never

• Annually

• Quarterly

• Monthly

• When topical

• Other​

14. Which service or program offered by the OCIEC has the greatest added value in terms of supporting you in meeting your compliance requirements?​
Please only state the top item that comes to mind​

15. Which role best describes you as a public office holder?​

• Head of Department, Agency, Crown Corporation or another federal organization

• Ministerial Staff

• Full-time Tribunal/Board/Commissions Member

• Part-time Tribunal/Board/Commissions Member

• Embassy/Consulate Staff

• Other

​16. Approximately how long have you been a public office holder?​

• Not applicable​

• Less than 1 year

• 1 to 5 years

• 6 to 10 years

• 11 to 15 years

• Over 15 years

17. Do you have any additional suggestions or comments for the OCIEC that could help us better serve you?​