Message from the Commissioner
I am proud to introduce the Office of the Conflict of Interest and Ethics Commissioner's first accessibility plan. Recognizing that accessibility for all is a critical element of inclusion, the Office is taking action to eliminate barriers in its operations and service delivery in accordance with the Accessible Canada Act.
This law aims for the full and equal participation of all persons, especially persons with disabilities, in Canada. It recognizes that people are not disabled by their conditions, but instead by environments that are neither accessible, welcoming nor enabling.
The Office's three-year plan maps out how we will improve accessibility in the seven key areas identified in the Accessibility Canada Act: employment; the built environment; information and communication technologies; communication; the procurement of goods, services and facilities; the design and delivery of programs and services; and transportation. It reflects the Office's commitment to create an accessible work environment and a diverse and inclusive workforce, as established in our
Code of Values.
As part of the Office's work towards identifying, preventing and eliminating accessibility barriers for our employees and stakeholders, we have held broad consultations to develop this plan. We welcome feedback at any time about accessibility at the Office to help us continue to identify, prevent and eliminate barriers and ensure use of best practices.
Accessible Canada Act is a law that came into force in July 2019. Its aim is to identify, remove and prevent barriers to accessibility and to make Canada barrier-free by January 1, 2040.
In accordance with this law, the Office of the Conflict of Interest and Ethics Commissioner (Office) must prepare and publish an accessibility plan showing how it identifies, will remove and prevent barriers. This version of the plan must be kept online for seven years after publication, and updated versions must be published every three years. Persons with disabilities must be consulted in the preparation of the accessibility plan and every updated version. The plan must describe the manner in which this consultation took place. The Office must provide alternate formats of this plan to people who request it.
This accessibility plan concerns the Office's policies, programs, practices, and services. It aims to identify and remove barriers, and to prevent new barriers from emerging in the areas described in section 5 of the Accessible Canada Act.
In approaching its responsibilities under the Accessible Canada Act and in the development of this plan, the Office embraced the guiding principle of “nothing without us." This means that people with disabilities are engaged and involved in the identification, prevention, and removal of barriers.
The Office also prepared this plan in accordance with the principles enumerated at section 6 of the law, that:
everyone must be treated with dignity;
everyone must have the same opportunity to make for themselves the life they are able and wish to have;
everyone must be able to participate fully and equally in society;
everyone must have meaningful options and be free to make their own choices, with support if they desire;
laws, policies, programs, services, and structures must take into account the ways that different kinds of barriers and discrimination intersect;
persons with disabilities must be involved in the development and design of laws, policies, programs, services, and structures; and
accessibility standards and regulations must be made with the goal of achieving the highest level of accessibility.
1.2. Statement of Commitment
The Office is committed to meeting all of its obligations under the Accessible Canada Act and its regulations (the Accessible Canada Regulations). By establishing a working group on accessibility and by continuing to consult persons with disabilities, the Office is committed to the proactive identification, removal and prevention of barriers to accessibility at the workplace and in all aspects of its communications and activities. Accessibility neither begins nor ends with this plan; it is an ongoing process. We strive to continuously improve accessibility in everything we do.
1.3. Contact Information and Feedback Process
The Office welcomes feedback, including feedback submitted anonymously, about accessibility at the Office and about this plan. We are committed to reviewing the feedback we receive in good faith and to taking steps to address, remove and prevent barriers to accessibility that are identified through this feedback.
Feedback about either accessibility at the Office or this plan may be submitted in the following way:
By contacting the Office's Manager, Human Resources Client Services, Corporate Management, using the information below:
Manager, Human Resources Client Services
Office of the Conflict of Interest and Ethics Commissioner
66 Slater St, 22nd Floor
Ottawa, Ontario K1A 0A6
The Office must keep the most recent version of the description of its feedback process for seven years after it is published or until a new description is published.
The Office will acknowledge the feedback it received in the same way that it was sent to it, unless it was sent by an anonymous source. The Office will review all feedback received and take steps to address barriers to accessibility that are identified. A copy of any feedback received must be kept for seven years.
Alternative formats of this plan and/or a description of the feedback process, can be requested by contacting
accessibleCIE@cie.parl.gc.ca or 613-995-0721.
In accordance with the regulations, the Office will provide the following alternative formats within 15 days of the initial request:
In accordance with the regulations, the Office will provide the following alternative formats within 45 days of the initial request:
The following definitions apply throughout this plan:
Barrier: Anything that might hinder the full and equal participation in society by people with disabilities. Barriers can be physical, architectural, technological, attitudinal, based on information or communications, or the result of a policy or procedure.
Disability: Any impairment or difference in physical, mental, intellectual, cognitive, learning, sensory, or communication abilities that, when interacting with a barrier, hinders a person's full and equal participation in society. Disabilities can be permanent, temporary, or change over time, and they may or may not be evident.
1.5. About the Commissioner and the Office
The Conflict of Interest and Ethics Commissioner administers the Conflict of Interest Act, a law that applies to public office holders and the Conflict of Interest Code for Members of the House of Commons, a code of conduct that applies to Members of Parliament that forms part of the rules of the House of Commons. These two regimes seek to prevent conflicts between private interests and the public duties of appointed and elected officials. The Commissioner also provides confidential advice to the Prime Minister about conflict of interest and ethics issues.
The position of Conflict of Interest and Ethics Commissioner was created following the adoption of the Federal Accountability Act in 2006. The Commissioner is an Officer of the House of Commons whose mandate is set out in the Parliament of Canada Act.
The Commissioner is completely independent of the government of the day and the Office is part of the parliamentary infrastructure.
The Commissioner is supported by an Office of approximately 50 employees who occupy positions related to compliance, investigations, legal services, communications, and corporate management.
1.6. Compliance with future standards
Accessibility Standards Canada is responsible for the development of accessibility standards for removing barriers to access faced by people with disabilities. These standards fall within the priority areas listed in the Accessible Canada Act.
This organization developed a document called Roadmap to 2040 – A plan to guide the work of Accessibility Standards Canada as a guide for its work.
At the time of the preparation of this plan, the Office is not aware of any standards that were completed or published.
As standards are completed by Accessibility Standards Canada and made publicly available on their website, the Office will review them as they are released and will adjust its plan to ensure that these standards are implemented.
1.7. Accessibility goals and the Accessibility Working Group
The aim of the Office is to complete the accessibility goals for each priority area described in Part 2 of this accessibility plan by the end of the year 2025.
To achieve the accessibility goals and to implement the plan, the Office created an accessibility working group chaired by the Manager, Human Resources Client Services, Corporate Management, and comprised of employees from the various divisions of the Office.
This working group will work closely with the Commissioner, the Senior Management Committee and the relevant directors of each division of the Office. In this way, timely approvals for the changes that will be necessary to give effect to the accessibility plan can be implemented within the deadline.
The working group will also:
monitor plan progress;
work with the Office's Manager, Human Resources Client Services, Corporate Management, to receive, acknowledge and review feedback on accessibility;
prepare the progress reports and update the accessibility plan; and
consult persons with disabilities.
2. Areas Described Under Section 5 of the Accessible Canada Act (ACA)
This priority area is about the importance of ensuring access to employment opportunities and an accessible workplace.
The Office is a separate employer whose employees are not part of the federal public administration.
The Office has its own terms and conditions of employment, relating to hours of work, employee benefits and general working conditions affecting employees. Employees are not covered under any collective agreement. The Office has a Joint Labour Relations Committee, consisting of management and employee representatives to ensure that any new or revised policy, directive and guideline related to human resources management is developed in consultation with all employees of the Office.
The Office is committed to employment equity and having a diverse and inclusive workforce. The Office's staffing processes and appointments are based on merit and are free from political influence.
All employees of the Office are expected to follow the values set out in its Code of Values and Standards of Conduct which reflect its commitment to diversity and inclusion.
The Office has adopted employment-related policies, in areas such as telework, occupational health and safety, procedures for emergency response, employee recognition, employee discipline, disability management and duty to accommodate, interchange Canada assignments, job shadowing, performance management, staffing procedures, training, termination and demotion, as well as on equity diversity and inclusion.
The Office reviews and updates its policies and guidelines in line with those of other parliamentary entities and the wider public service.
When carrying out its consultations, the Office was mindful that barriers that may arise in the context of employment could include, but were not limited to, those encountered during staffing processes, onboarding, promotion and/or career progression, or during workplace accommodation.
No barriers were identified in this area during consultation.
2.1.3. Accessibility Goals
The Office will consider adopting a systematic review of its employment practices, procedures and policies for accessibility.
The Office will aim to complete these accessibility goals by the end of 2025.
Review staffing tools, approaches, and policies to ensure that any barriers are identified and removed so as to make employment with the Office accessible and inclusive.
Review the Office's Guideline on Disability Management and Duty to Accommodate.
Continuously support the employee network groups, including the promotion of disability groups on the parliamentary Hill.
Provide access to training sessions for employees at all levels on accessibility, barriers, unconscious bias and accommodation requests and processes so they can build expertise.
2.2. The Built Environment
This priority area is about the accessibility of the built environment which has a significant impact on whether people with disabilities can move freely, access and function within a space in a manner equitable with those who do not have disabilities.
The primary location in which the Office conducts most of its activities is in downtown Ottawa at 66 Slater Street, Ottawa, Ontario on the 21st and 22nd floors. As a result of the pandemic and a new Telework Policy, employees of the Office may work from an approved alternate location.
Employees must sometimes access other buildings and office spaces throughout the National Capital Region (NCR).
At its primary location of work, the Office's lobby on the 22nd floor is accessed by using the building's elevators. There are also stairs that can be used from the building's ground floor to access the elevator lobbies of both the 21st and 22nd floors. Outside of the lobby, access to the office space requires use of a security card.
There are washrooms, including accessible washrooms, on both the 21st and 22nd floors.
There are automatic doors located in some of the common areas such as washrooms and main entrances.
The Office has also established and published Procedures for Emergency Response.
When carrying out its consultations, the Office was mindful that barriers that may arise in the context of the built environment could include, but were not limited to, physical or architectural barriers such as stairs, steps, curbs, doors that are too heavy or too narrow or that do not open in a certain direction or fully or automatically, lack of accessible bathroom stalls, inadequate lighting, poor acoustics, and no rest areas (benches).
The feedback the Office received from consultation raised concerns in the following areas:
Parts of the washrooms located on the 22nd floor, including the entrances, were identified as too narrow.
Washroom and stall doors were identified as creating issues as a result of the direction in which they open.
Some doors in the office space do not open automatically.
The signs in the office do not include braille.
There is a lack of sensory control over the in-office environment.
It was noted that the Office's hallways at 66 Slater Street were narrow and might not accommodate a person with a disability.
2.2.3. Accessibility Goals
The Office will aim to complete these accessibility goals by the end of 2025.
Ensure that the Office's planned change to its physical office space in the coming years will be in line with accessibility requirements, including by working with Public Services and Procurement Canada to prioritize taking steps that are necessary to correct and eliminate barriers.
Ensure that its office space will include signage standards meeting accessibility requirements and best practices, and develop plans to ensure a periodic review of its signs to correct and eliminate barriers.
Review and revisit accessibility as it relates to its built environment, including by making use of the accessibility feedback process, to ensure that new barriers have not been created and that existing accessibility features have been maintained.
Review its emergency procedures to incorporate information about emergency procedures for people with disabilities. The Office will also look at providing relevant training in this area to ensure that employees are aware of the emergency plans and who is responsible for assisting employees or visitors both inside our buildings and in the immediate surrounding area in case of an emergency.
2.3. Information and Communication Technologies (ICT)
This priority area is about offering accessible digital content and technologies.
Information and communication technologies are used to deliver and access information, perform activities, and provide services. They can include, but are not limited to, hardware, software, video or voice communication tools, and other digital content.
In support of public education about the regimes that it administers, the Office makes a range of digital information available on its website (HTML and PDF) and is active on social media (Twitter: @EthicsCanada).
The Office also has a non-public facing website used by its employees, an intranet site based on the SharePoint platform.
The Office is presently developing a new electronic system named “Nethik" to give regulatees—appointed and elected persons who must comply with the regimes administered by the Office—a fully secure, fast and easy way to submit required information to the Office. This system will also enhance the public registry of information that is made available by the Office to the public about certain private interests, gifts or travel of regulatees.
The Office, including its employees, also use email, Voice over Internet Protocol (VOIP), and software, such as MS Teams, to communicate and share information.
The Office has contractual agreements and works with the House of Commons related to the provision of information technology.
When carrying out its consultation, the Office was mindful that barriers that may arise in the context of information and communication technologies could include, but were not limited to, electronic documents without accessibility features or alternative text, incompatibilities with screen readers or other assistive devices, and fonts or colour contrasts on web-based applications or in emails that create difficulties accessing the content.
The following feedback was received:
Virtual meetings, and the tools used to conduct it, was identified as a barrier for communication and lacked features to enable accessibility.
It was noted that it is difficult to sometimes hear and lip read over video feeds.
Content shared during virtual meetings or presentations often appears in too small a font size or is otherwise difficult to read.
Some office electronic tools were identified as creating barriers, such as the use of tablets with small screen sizes.
Accessing information from the Office's databases or website requires many clicks.
The website was difficult to navigate and it was too hard to locate the information one may be looking for.
Font displays and font colours on the Office's website and electronic tools create barriers for reading and accessing the content.
Some identified cognitive barriers as being important to consider in this area.
Some identified that HTML should be used by default as it interacts well with readers and other “out-loud" technologies.
2.3.3. Accessibility Goals
The Office will aim to complete these accessibility goals by the end of 2025:
Ensure that all the Office's online platforms are accessible for all users.
Identify and address accessibility gaps with the Office's website and update it to comply with the new WCAG2.2 criteria.
Develop a plan to review all internal and external documents and forms for accessibility.
Plan for a review of all software applications developed in-house or acquired from third parties in order to identify and remove any potential accessibility barriers and to determine how they interact with adaptive technology.
2.4. Communication, Other Than ICT
This priority area is about creating barrier-free spaces where everyone can communicate, share and access information. Accessible communication can involve clear, direct and plain language. Information can also be offered in different formats to enhance accessibility.
The Office communicates with regulatees, the media and members of the public whether by phone, email, post, fax, through publication of reports, guidelines and information notices, as well as in person, through presentations or through direct messages on Twitter.
The Office has developed procedures and processes to ensure that it provides accurate, timely and useful information to the individuals and groups seeking information.
When carrying out its consultation, the Office was mindful that barriers that may arise in the context of communication (other than ICT) could include, but were not limited to, font or print that is too small or hard to read, no alternative access to the content of graphs or charts, lack of use of plain language, instructions that are confusing or complicated, presentations that are not fully accessible, seating arrangements that exclude people from participating fully in the communication process.
The feedback the Office received in this area included that:
It is difficult to understand the rules and the definitions used and referred to by the Office.
Information should be easier to understand, in plain language and in point form.
2.4.3. Accessibility Goals
The Office will aim to complete these accessibility goals by the end of 2025.
Develop and implement plain language guidelines for the Office's publications and communications.
Develop and implement accessibility guidelines for its communications (including presentations, publications and images).
2.5. Procurement of Goods, Services, and Facilities
This priority area is about making accessibility an important component of the procurement process and about ensuring that the Office purchases accessible goods, services and facilities.
Procurement refers to the acquisition of goods and services by any means, including purchase, rental, lease or conditional sale.
For the Office, procurement is done in accordance with the Office's Directive on the Procurement of Goods and Services, Policy on the Delegation of Financial Signing Authorities, Directive on Acquisition Cards, and the Directive on Petty Cash.
The current procurement directive mentions an objective of enhancing access and includes a requirement for following ethical practices.
As set out in its financial reports, the Office enters into transactions with other government and parliamentary entities in the normal course of business and on normal trade terms. For example, the Office has agreements with the House of Commons related to the provision of information technology and security services, and the Public Services and Procurement Canada related to the provision of compensation services.
When carrying out its consultation, the Office was mindful that barriers that may arise in the context of procurement of goods, services, and facilities could include, but were not limited to whether a good or service can be used by persons in different positions (seated, standing), with different levels of strength or range of body movement, with hearing or vision loss; whether support materials, such as manuals, are accessible in other formats; whether products can be customized or work with other accessible technologies; whether the organization providing the good or service provide accessible customer support; whether there are accessibility requirement clauses set out in contracts or Office policies concerning contracting.
There was no feedback received in respect of the Office's procurement.
2.5.3. Accessibility Goals
The Office will aim to complete these accessibility goals by the end of 2025.
Review the current procurement directive and related policies to incorporate accessibility considerations.
Review the inventory of current goods and services and enquire about the accessibility practices and services of current suppliers.
2.6. Design and Delivery of Programs and Services
This priority area is about ensuring that everyone can receive and access the services and programs delivered by the Office. The key programs and services delivered by the Office involve:
reporting to the Prime Minister and to Parliament;
helping regulatees achieve and maintain compliance with the conflict of interest regimes;
giving regulatees confidential guidance tailored to their individual situations;
helping regulatees understand their obligations under the regimes through education and outreach;
applying investigations and other enforcement provisions as appropriate;
exchanging information with domestic and international counterparts;
providing programs and services to employees.
When carrying out its consultations the Office was mindful that barriers that may arise in the context of design and delivery of programs and services could include, but were not limited to a lack of diverse channels for delivering services (e.g., over the phone, in-person, email, reports).
The Office received no feedback in this area.
2.6.3. Accessibility Goals
The Office will aim to complete this accessibility goal by the end of 2025.
Provide employees with appropriate tools and training to make accessibility a key consideration in all future programs and services.
This priority area aims to create a barrier-free federal transportation network.
While the Office does not provide transportation services, travel on behalf of the Office may from time-to-time form part of an employee's official duties. In this context, the Office has Guidelines on Travel, a Directive on Travel and Conference Expenditures, Guidelines for the Approval of Travel for the Conflict of Interest and Ethics Commissioner, the National Joint Council Travel Directive, the Code of Values and Standards of Conduct for employees of the Office and other internal policies or directives related to financial management.
The primary place of work for the Office, 66 Slater Street, is located in downtown Ottawa. It is accessible by public transit and the building has underground public parking operated and managed by a third party and includes access to the building's elevators. Parking is also available at the National Arts Centre across the street from the building.
The Office has guidelines on parking and the use of parking passes by employees.
As a result of its location, offloading and onloading from vehicles as well as vehicle passenger drop-off or pick-up can be challenging outside of the building.
When carrying out its consultations, the Office was mindful that barriers that may arise in the context of transportation could include, but were not limited to those that result from long work-related travel distances, adverse policies affecting travel, lack of accessible seating, alternative service options, lack of or confusing signs and directions.
The Office received no feedback in this area.
2.7.3. Accessibility Goals
Review policies and guidelines related to employee travel to identify and remove any accessibility barriers to ensure that all employees travel safely regardless of disability.
Update guidelines on parking and the use of parking passes by employees to include accessibility standards, including as to how parking spaces are attributed.
Employees at all levels of the Office and stakeholders, including the general public, were consulted for the purposes of informing this accessibility plan.
Through these consultations, each person was offered the opportunity to provide anonymized accessibility feedback through a survey in the areas described under section 5 of the Accessible Canada Act. They were also provided with an alternative method for contacting the Office with questions or comments about accessibility.
During the consultation with the employees, this group was asked:
to describe any barriers that they have encountered or observed at the Office. They were asked if the barrier was physical, and if so, where it was located.
if the barrier was technology-related, and if so, how it occurred.
for any suggestions on how to remove barriers they identified.
what they would prioritize in terms of barrier removal.
about what the Office was doing well in terms of accessibility.
to provide the name of any entity or organization that they felt could help the Office improve accessibility.
There was a 35% feedback response rate from the employees of the Office. This feedback informed the plan and the accessibility goals. Of those who responded, approximately 20% identified as persons living with a disability and/or a person needing an accommodation.
From September 7 until October 2, 2022, the Office requested that each employee include as part of their electronic signature the following information to solicit feedback from the Office's stakeholders, including the general public:
“The Office is conducting an optional accessibility survey until October 2, 2022. We welcome your input as we aim to remove barriers to a person's ability to receive appropriate and timely services from the Office. The accessibility survey is located on our website at this link."
« Le Commissariat mène un sondage facultatif sur l'accessibilité jusqu'au 2 octobre 2022. Nous accueillons vos commentaires puisque nous visons à éliminer les obstacles qui empêchent les gens de recevoir des services appropriés et en temps opportun de la part du Commissariat. Le sondage sur l'accessibilité est situé sur notre site Web à ce lien. »
In this survey, the Office continued to ask about the areas described in section 5 of the Accessible Canada Act, with particular attention to whether any barriers were faced or observed:
at 66 Slater Street, the Office's primary location of work;
concerning the digital presence of the Office;
concerning dealings/communications with the Office;
The stakeholders were asked about areas where the Office may not be doing so well accessibility-wise and about what the Office might be doing well accessibility-wise.
As a result of this consultation, the Office received six responses. Five identified as being from the general public and one as an employee of a Member of Parliament. Four of the six respondents identified as a person with a disability.
3.3. Parliamentary Precinct Working Group
Over the past year, the Office regularly participated in bi-weekly meetings on accessibility with representatives of other parliamentary precinct entities.
The purpose of these meetings was to share experiences, share feedback on consultations with persons with disabilities who have had dealings with parliamentary entities and advocacy groups, and to share information to help align an approach to accessibility by parliamentary entities.
The information shared at this working group was greatly appreciated and was instrumental in the preparation of this plan.
3.4. Groups representing persons with disabilities
In the preparation of this plan, the Office also reached out directly to groups representing persons with disabilities, by making use of the list available on the
People Access – Making accessibility easier webpage.
At the time of publication of this plan, the Office did not yet receive feedback from the groups it had approached for consultation. However, many of these groups were also approached by other parliamentary entities and the representatives of these entities gave permission to the Office during a parliamentary precinct working group session to refer to the general feedback they received because of these consultations. The feedback they shared was considered in the preparation of the accessibility goals set out in this plan.
4. Summary of Goals – 2023-2025
In summary, the Office will aim to complete these accessibility goals by the end of 2025.
Long term (2023-2025)
Medium term (2023-2024)
Short term (2023)
1) Review staffing tools, approaches, and policies to ensure that any barriers are identified and removed so as to make employment with the Office accessible and inclusive.
2) Review the Guideline on Disability Management and Duty to Accommodate.
3) Continuously support the employee network groups, including the promotion of disability groups on the parliamentary Hill.
Provide access to training sessions for employees at all levels, as per the Guidelines on Learning, Training and Development, on accessibility, barriers, unconscious bias and accommodation requests and processes so they can build expertise.
2.2.3. Built Environment
1) Ensure that the Office’s planned change to its physical office space in the coming years will be in line with accessibility requirements, including by working with Public Services and Procurement Canada to prioritize taking steps that are necessary to correct and eliminate barriers.
2) Ensure that its office space will include signage standards meeting accessibility requirements and best practices, and develop plans to ensure a periodic review of its signs to correct and eliminate barriers.
3) Review and revisit accessibility as it relates to its built environment, including by making use of the accessibility feedback process, to ensure that new barriers have not been created and that existing accessibility features have been maintained.
4) Review its emergency procedures to incorporate information about emergency procedures for people with disabilities. The Office will also look at providing relevant training in this area to ensure that employees are aware of the emergency plans and who is responsible for assisting employees or visitors both inside our buildings and in the immediate surrounding area in case of an emergency.
2.3.3. Information and Communication Technologies (ICT)
1) Ensure that all the Office’s online platforms are accessible for all users.
2) Identify and address accessibility gaps with the Office’s website and update it to comply with the new WCAG2.2 criteria.
3) Develop a plan to review all internal and external documents and forms for accessibility.
4) Plan for a review of all software applications developed in-house or acquired from third parties in order to identify and remove any potential accessibility barriers and to determine how they interact with adaptive technology.
2.4.3. Communication, Other Than ICT
1) Develop and implement plain language guidelines for the Office’s publications and communications.
2) Develop and implement accessibility guidelines for its communications (including presentations, publications and images).
2.5.3. Procurement of Goods, Services, and Facilities
1) Review the current procurement directive and related policies to incorporate accessibility considerations.
2) Review the inventory of current goods and services and enquire about the accessibility practices and services of current suppliers.
2.6.3. Design and Delivery of Programs and Services
1) Provide employees with appropriate tools and training to make accessibility a key consideration in all future programs and services.
1) Review policies and guidelines related to employee travel to identify and remove any accessibility barriers to ensure that all employees travel safely regardless of disability.
2) Update guidelines on parking and the use of parking passes by employees to include accessibility standards, including as to how parking spaces are attributed.
COMPLETE THE FEEDBACK SURVEY.
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