1. General
1.1 Overview
The Office of the Conflict of Interest and Ethics Commissioner recognizes the importance of accessibility and to provide a barrier-free environment in the work place. The Office published its accessibility plan on December 15, 2022. This report and other resources are available on our website and are available upon request in alternative formats.
Contact Information and Feedback Process
The Office welcomes feedback, including feedback submitted anonymously, about accessibility at the Office and about this progress report. 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 progress report may be submitted in the following ways:
- 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
AccessibleCIE@cie.parl.gc.ca
613-995-0721
-
By completing the online accessibility feedback survey. Alternate formats of the survey can be requested by emailing us or calling us at 613-995-0721.
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 progress report and/or a description of the feedback process, can be requested by
emailing us or calling us at 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:
1.2 Definitions
The following definitions apply throughout this progress report:
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.
1.3 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 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.
1.4 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 progress report, the Office is aware that 12 standards are in development, some have completed a first public review while others are pending. 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 actions to ensure that these standards are implemented.
1.5 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 the 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.
The working group:
monitors the implementation of the accessibility goals outlined in the plan;
works with the Office's Manager, Human Resources Client Services, Corporate Management, to receive, acknowledge and review feedback on accessibility;
writes the progress reports; and
consults persons with disabilities.
2. Areas Described Under Section 5 of the Accessible Canada Act (ACA)
2.1 Employment
2.1.1 Overview
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 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.
2.1.2 Progress on Accessibility Goals
The Office adopted a systematic review of its employment practices, procedures, and policies for accessibility in the past year.
The Office received feedback for this area on the employee survey of the Office's progress and results can be found in section 4 (Feedback). The Office is on track to complete its accessibility goals related to this area by the end of 2025.
Accessibility Goals
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.
Progress
The terms and conditions of employment are being revised to identify and, as necessary, remove any accessibility barriers. As part of this exercise, the Office will have regard to other federal employers' and parliamentary entities latest terms and conditions of employment.
Staffing processes continue to ensure that every candidate and participant's accessibility needs are met by identifying on job poster that they can communicate requests for accommodations to Human Resources.
2. Review the Guideline on Disability Management and Duty to Accommodate.
Progress
The Office has completed its review of the Guideline and it was determined that the document still reflects best practices. The Office is aware that other parliamentary entities are revising their guidelines and once that exercise is completed, we will take that opportunity to review our own Guideline to incorporate any new best practices.
3. Continuously support the employee network groups, including the promotion of disability groups on the parliamentary Hill.
Progress
The Office continues to regularly participate in meetings on accessibility with representatives of the Parliamentary Precinct Universal Accessibility Working Group. The information shared at this working group is communicated with employees in various ways such as office-wide meetings and the intranet. Collaboration efforts with this group will continue in 2024.
4. 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.
Progress
The Office provides employees with access to the Canada School of Public Service training database and regularly communicates to employees new accessible training opportunities from various organizations, including Eliminating Barriers: Lessons Learned in Accessibility, and Addressing Disability Inclusion and Barriers to Accessibility. Efforts and collaboration will continue in the future.
2.2 The Built Environment
2.2.1 Overview
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 22nd floor. Since most employees are in a hybrid environment, in 2023 the Office decided to reduce its work environment to one floor. The Telework Policy is still in place, 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.
At its primary location of work, the Office's lobby on the 22nd floor is accessed by using the building's elevators. Outside of the lobby on the 22nd floor, access to the office space requires use of a security card.
There are washrooms, including accessible washroom, on the 22nd floor.
There are automatic doors located in some of the common areas such as washrooms and main entrances.
The Office has Procedures for Emergency Response and an active Health and Safety Committee.
2.2.2 Progress on Accessibility Goals
The Office is in the process of moving from two floors (21st and 22nd floors) to a single floor (23rd floor). The floor plans have been approved, with accessibility considerations at the forefront of the project, and construction will be underway in the next year.
The Office received feedback for this area on the employee survey of the Office's progress and results can be found in section 4 (Feedback). The Office is on track to complete its accessibility goals related to this area by the end of 2025.
Accessibility Goals
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.
Progress
In the planning for the move to the 23rd floor, Public Services and Procurement Canada has engaged the services of an accessibility expert, to ensure the office's physical environment meets all accessibility codes and regulations.
While construction is underway, the 22nd floor is currently the designated work location for the Office. A defibrillator and a stairway evacuation chair are located on the 22nd floor.
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.
Progress
In designing the 23rd floor, the Office is looking towards digital signage, where possible. Using digital signage allows the office to be adaptable to individuals with varying visual impairments. In the instances where digital signage is not possible, accessibility experts will be engaged to ensure we meet or exceed legislation, codes, and regulations.
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.
Progress
In finalizing the plans for its move to the 23rd floor, the Office remains mindful of its goal to keep the current accessibility standards, while ensuring that the move does not create any new barriers. To achieve this, the Office will continue to encourage employees to use the feedback loop, and will ensure that it is maintained and monitored.
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.
Progress
The Office's Health and Safety Committee revised its emergency procedures with accessibility needs in mind. These procedures were strategically posted on Office premises, as well as on the Office's intranet. Training remains available for employees who have volunteered to be fire wardens during an evacuation.
2.3 Information and Communication Technologies (ICT)
2.3.1 Overview
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.
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.
2.3.2 Progress on Accessibility Goals
The Office is in the process of implementing Web Content Accessibility Guidelines (WCAG2.2).
The Office received feedback for this area on the employee survey of the Office's progress and results can be found in section 4 (Feedback). The Office is on track to complete its accessibility goals related to this area by the end of 2025.
Accessibility Goals
1. Ensure that all the Office's online platforms are accessible for all users.
Progress
We have agreements in place with our parliamentary partners, who have engaged accessibility experts, to build, develop, maintain, and renew all of our online platforms. The redesigned platforms will adopt, to the greatest extent possible, accessibility standards and best practices in effect at the time of development, redevelopment or renewal.
2. Identify and address accessibility gaps with the Office's website and update it to comply with the new WCAG2.2 criteria.
Progress
The Office is in the process of redeveloping its website with parliamentary partners and will ensure that it conforms, to the greatest extent possible, with the new WCAG2.2 criteria.
3. Develop a plan to review all internal and external documents and forms for accessibility.
Progress
An employee responsible for desktop publishing has completed training on how to make the Office's documents more accessible. A plan will be developed to help identify and ensure that internal and external documents and forms are as accessible as possible.
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.
Progress
As described in the first goal, systems and applications are being redeveloped with parliamentary partners, who engaged accessibility experts, to ensure that accessibility standards and practices will be adopted.
2.4 Communication, Other Than ICT
2.4.1 Overview
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 social media.
The Office has developed procedures and processes to ensure that it provides accurate, timely and useful information to the individuals and groups seeking information.
2.4.2 Progress on Accessibility Goals
The Office has developed and implemented accessibility guidelines around its communications, with a strong focus on plain language.
The Office received feedback for this area on the employee survey of the Office's progress and results can be found in section 4 (Feedback). The Office is on track to complete its accessibility goals related to this area by the end of 2025.
Accessibility Goals
1. Develop and implement plain language guidelines for the Office's publications and communications.
Progress
In the past year, the Office's Internal Communications Working Group organized a series of plain language educational sessions to help employees communicate more clearly among themselves and with outside audiences. This working group also launched a plain language audit to review the Office's communication products and ensure they meet plain language principles. Finally, the Office's Style Guide was also updated in both official languages to include guidelines on plain language to help employees communicate in a way that allows people to access, understand, and use the information the Office shares. The plain language guidelines will be applied going forward.
2. Develop and implement accessibility guidelines for its communications (including presentations, publications and images).
Progress
The Office has adopted the Government of Canada's Guidelines on Making Communications Products and Activities Accessible as well as the Directive on the Management of Communications in the designing and development of its communications products. This includes using plain language, applying clear and consistent layouts, designing and formatting PDF and Word documents to be accessible, writing alternative text for informative and decorative visuals, among other considerations.
2.5 Procurement of Goods, Services, and Facilities
2.5.1 Overview
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, and the Directive on Acquisition Cards.
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.
2.5.2 Progress on Accessibility Goals
The Office has reviewed its procedures related to procurement of goods, services offered, and facilities being used with accessibility goals in mind.
The Office received some feedback on its accessibility goals related to procurement of goods, services, and facilities and is on track to complete these accessibility goals by the end of 2025.
Accessibility Goals
1. Review the current procurement directive and related policies to incorporate accessibility considerations.
Progress
Further to a review, this goal requires more time to complete.
2. Review the inventory of current goods and services and enquire about the accessibility practices and services of current suppliers.
Progress
The Office has reached out to a number of suppliers to enquire about their accessibility practices and services. It was communicated by suppliers that accessible services are available as necessary.
2.6 Design and Delivery of Programs and Services
2.6.1 Overview
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.
2.6.2 Progress on Accessibility Goals
The Office received no feedback about barriers related to design and delivery of programs and services and is on track to complete the following accessibility goal by the end of 2025.
Accessibility Goal
1. Provide employees with appropriate tools and training to make accessibility a key consideration in all future programs and services.
Progress
The Office provided accessibility training opportunities to employees and continues to look for more ways to incorporate the lessons learned in its delivery of programs and services.
2.7 Transportation
2.7.1 Overview
This priority area aims to create a barrier-free federal transportation network.
While the Office still 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 that consider accessibility, as well as 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 which is also accessible.
The Office has guidelines on parking and the use of parking passes by employees.
As a result of its location, onloading and offloading from vehicles as well as passenger drop-off or pick-up can be challenging outside of the building.
2.7.2 Progress on Accessibility Goals
The Office has conducted a review and identified that more work is needed to incorporate accessibility considerations in its directives and guidelines relating to transportation.
The Office received no feedback on its accessibility goals related to transportation and is on track to complete its accessibility goals by 2025:
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.
Progress
While the Office completed an initial review of its guidelines relating to transportation, namely the Guidelines on Travel; Directive on Travel and Conference Expenditures; Guidelines for the Approval of Travel for the Conflict of Interest and Ethics Commissioner, a further review will be needed to address accessibility considerations.
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.
Progress
The Office is reviewing its parking guidelines and is considering ways to incorporate accessibility measures.
3. Consultations
Since the publication of the Accessibility Plan last year, employees at all levels of the Office were consulted for the purposes of informing this progress report.
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.
During the consultation with the employees, this group was asked:
to consult the accessibility goals set out in the plan to describe any barriers that they have encountered or observed at the Office;
for any suggestions on how to remove barriers they identified;
what they would prioritize in terms of barrier removal;
what the Office was doing well in terms of accessibility.
The feedback from the survey informed this progress report. The feedback is summarized in the next section. Persons living with a disability are among those who provided feedback.
Consultations were also held with key partners in the parliamentary community.
Over the past year, the Office regularly participated in meetings on accessibility with representatives of other parliamentary precinct entities.
The purpose of these meetings was to share experiences, particularly in the drafting of the progress reports, 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 progress report.
4. Feedback received
During the past year, the Office received only one request using the feedback process. The request related to obtaining a copy of the accessibility plan in a separate format. The Office promptly provided the plan as requested.
Because only one request was received, the Office will consider ways to improve awareness about its feedback process in the year ahead.
Through the employee survey of the Office's progress in terms of accessibility, the Office consulted with employees, including those identified as living with disabilities. The areas in which barriers were identified are the following:
Built Environment: seeing to acoustic/sound efficiency, ensuring scent-free environment, organizing and standardizing meeting room and offices until the Office moves to the 23rd floor.
Employment: a return to an in-person or a hybrid work format may result in barriers on accessibility, this may be addressed through greater consultation.
Information and Communication Technologies (ICT): improving usability of the Office website and streamlining text.
Communication, Other than ICT: when information is being shared with employees, ensuring that it is done in an inclusive manner.
Procurement of Goods, Services, and Facilities: ensuring that all necessary office supplies are provided and stored in an accessible way.
Overall employees felt like the Office was on track to meet its accessibility goals. They are interested in obtaining more training on accessibility.
The feedback we received confirms the importance of several initiatives already captured in the accessibility plan and the barriers that were identified will help pinpoint areas where further consultation would be beneficial.