I am pleased to submit to you my rep​ort on the performance of my duties and functions under the Conflict of Interest Act in relation to public office holders for the fiscal year ending March 31, 2022, for tabling in the Senate. 

The Office's stakeholders include regulatees—the individuals subject to the conflict of interest regimes it administers—as well as Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. 

This report touches on all stakeholder groups, but its focus is on​ the public office holders who are subject to the Conflict of Interest Act. They are key stakeholders of the Office. 

In support of stakeholder communications and engagement, a key focus area of the Office's 2021-2024 strategic plan, the Office updated its list of stakeholders to allow for timely, proactive and fine-tuned messaging. As part of this project, it identified a new category of stakeholders dubbed “accelerators." These are entities or groups that are not subject to the Conflict of Interest Act or the Conflict of Interest Code for Members of the House of Commons​ but play a role in educational activities for regulatees. Examples are secretariats for administrative tribunal boards and organizers of events linked to Governor-in-Council appointees. By engaging more actively with accelerators, the Office can better adapt its outreach and education activities to the needs of regulatees. 

One of the Office's strategic objectives is to increase trust in and credibility of the Office with key stakeholders so they become stronger allies in the delivery of its mandate and can effectively manage conflict of interest issues. An important purpose of the stakeholders list project was to assess regulatees' individual needs to help improve education, outreach and service delivery. The Office also surveyed public office holders in January 2022 and will use the results to help optimize service delivery. 

EDUCATIO​​N AND OUTREACH 

The Commissioner discussed the importance of education in a January 2022 op-ed published in The Hill Times. He noted that complying with the Conflict of Interest Act is not about avoiding penalties but about doing the right thing and encouraged public office holders to educate themselves about the Act's rules.  

In May 2021, the Office issued an updated information notice on reimbursement of costs associated with divestment of assets and withdrawal from activities. In October 2021, it issued an information notice on the meaning of “friendship" for the purposes of the Act. While noting that the Commissioner determines the existence of a friendship on a case-by-case basis, it sets out several indicators that may help determine whether an individual is a friend within the meaning of the Act. It also discusses public office holders' obligations under the Act when it comes to friendships. 

The Office gave 19 presentations to offices and organizations with regulatees subject to the Act in 2021-2022, almost double the number of presentations compared to the previous year, reaching almost 600 regulatees​. Regulatees can request presentations for their organizations by contacting the Office, and advisors may offer presentations when speaking to regulatees. 

The Office has found that online educa​​tional sessions offer a convenient and flexible way to deliver training. They enable it to reach more regulatees whose busy schedules might not permit them to attend in-person sessions. And they make it possible for participants to pose questions anonymously. Providing online training is also feasible within the Office's current resourcing levels, as the technology is provided by the House of Commons IT team. 

In June 2021, the Office hosted two teleconferences (one each in English and in French) on offers of outside employment and recusals. In December 2021, the Commissioner hosted a teleconference on post-employment rules and offers of outside employment for ministerial staff. In early January 2022, several ministerial offices asked for a presentation for their ministerial staff. Given the number of requests and the number of new ministerial staff who were being onboarded, the Office set up one educational session in each official language to handle the numerous requests and consulted with the ministerial offices on the most appropriate timing and topic. Therefore, in March 2022, prompted by a high volume of information requests from ministers’ offices, another educational session was offered to ministerial staff, providing an overview of their obligations with a focus on the items that should be kept top of mind. There were 170 participants in this session. A doubling of the number of firm offers and acceptances of outside employment disclosed to the Office in 2021-2022 compared to the previous year indicates that better awareness of the rules results in improved compliance.​

The Office reached out to public office holders on Twitter (@EthicsCanada) as an additional means of helping them understand their obligations under the Act and how to comply with it. Its social media posts are not meant to replace other communications but serves to supplement current education practices such as personalized emails from advisors, general emails from the Commissioner and information notice​​s on the website. Indeed, the January 2022 survey of public office holders revealed that only 30% of regulatees rely on Twitter as a source of information about the conflict of interest regimes administered by the Office. This is in line with statistics on Canadians' reliance on Twitter as a news source. 

ENFORCEMENT

While the Office seeks to ensure full compliance with the Conflict of Interest Act, there are several enforcement mechanisms available to address non-compliance and the Commissioner does not hesitate to apply them as necessary. Their application serves to encourage compliance rather than to punish. 

The January 2022 survey of public office holders revealed that some do not view the Act's rules as flexible and that they do not reflect their positions since the same rules apply to all reporting office holders— from interns in a minister's office to ministers themselves. There is an opportunity for the Office to better explain the reasoning behind these rules to foster more understanding. 

Administrative Monetar​​y Penalties 

The Commissioner can impose administrative monetary penalties of up to $500 for failures to meet certain reporting requirements of the Act within established  deadlines. 

In 2021-2022, the Office issued 18 administrative monetary penalties, seven more than in the previous year. It also updated its procedures to give public office holders the option of paying penalties by credit card. 

When an administrative monetary penalty is issued, the Act requires the Commissioner to make public the nature of the violation, the name of the public office holder and the amount of the penalty. The Office posts penalties in the public registry and publishes them on social media. Tweeting administrative monetary penalties supports the  Commissioner's commitment to openness and transparency and can also have a deterrent effect. The Office's tweets relating to penalties tend to generate higher engagement rates on average than its general informational tweets but are seen by fewer Twitter users. 

Compliance O​rders

Under section 30 of the Act, the Commissioner may order a public office holder to take any compliance measure to comply with the Act, such as submitting documents for their annual review, divesting controlledassets or ceasing prohibited activities. 

The Commissioner issued 15 compliance orders in 2021-2022, five more than in the previous year. Like administrative monetary penalties, compliance orders are posted in the public registry and may be shared on social media. 

Examinatio​ns

Under sect​io​n 44 of the Act, the Commissioner can launch an examination of a possible contravention of the Act at the request of a Senator or Member of the House of Commons who provides reasonable grounds to believe  the Act has been contravened. The Office received nine requests for investigations under the Act from Members in 2021-2022.  

Under s​ection 45, the Commissioner may conduct an examination on his own initiative if he has reason to believe that a current or former public office holder has contravened the Act. The Commissioner may decide to do so based on information from various sources, including media reports and complaints from members of the public. The Commissioner also has the discretion to conduct an inquiry on his own initiative. The Office received 15 requests for examinations under the Act from members of the public in 2021-2022.  

The Commissioner issues a public report when an examination is completed. When the Commissioner decides to discontinue an examination launched under section 44 of the Act, a discontinuance report is issued. However, when the Commissioner discontinues an examination launched under section 45, he is not required to issue a report. 

In 2021-2022, the Office issued two examination reports under the Act. 

One focused on the conduct of the Right Honourable Justin Trudeau, Prime Minister of Canada. The other focused on the conduct of the Honourable Bill Morneau while he was Minister of Finance. 

Both reports, which were issued on May 13, 2021, related to two matters involving the private interests of WE, an international development charity and youth empowerment movement founded by Messrs. Marc and Craig Kielburger. It had been alleged that Mr. Trudeau and his relatives were involved with WE and that the Morneau family had close ties with WE. One of the matters was a decision to award WE the administration of the Canada Student Service Grant (CSSG), a proposed government student relief initiative to encourage youth to participate in national service in the context of the COVID-19 pandemic. The other was a decision to fund WE's proposed Social Entrepreneurship program, a digital program providing entrepreneurship expertise and mentorship opportunities. 

Both reports also focused on the same provisions of the Act: subsection 6(1), section 7 and section 21. 

Subsection 6(1) prohibits public office holders from making or participating in the making of a decision that would place them in a conflict of interest. Section 4 states that a public office holder is in a conflict of interest when they exercise an official power, duty or function that provides an opportunity to further their private interests or those of their relatives or friends or to improperly further another person's private interests. 

Section 7 prohibits public office holders from giving preferential treatment to a person or organization based on the identity of a representative of the person or organization. 

Section 21 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. 

In the Trudeau III Report, the Commissioner found that Mr. Trudeau did not contravene subsection 6(1), section 7 or section 21 of the Act.  

For a contravention of section 7 to occur, the treatment a public office holder gives to a person or organization must be more favourable than the treatment they might give to a similarly situated person or organization, and there must be a prior relationship between the public office holder and the representative. Mr. Trudeau's decision to approve the CSSG proposal with WE as the administrator of the program was not, in the Commissioner's view, motivated by the identity of any third-party representative, given the absence of a personal relationship between Mr. Trudeau and Messrs. Marc and Craig Kielburger. The Commissioner was satisfied that Mr. Trudeau did not give preferential treatment to WE and therefore did not contravene section 7 of the Act. 

The Commissioner was satisfied that there was no opportunity to further Mr. Trudeau's own interests or those of his relatives from WE's role as administrator of the CSSG or from its Social Entrepreneurship proposal. He determined that Mr. Trudeau had the opportunity to further WE's private interests regarding its Social Entrepreneurship proposal and its selection as the administrator of the CSSG. However, for there to be a contravention of subsection 6(1), WE's private interests would have to have been furthered improperly. In the Commissioner's view, there was no evidence of impropriety in relation to Mr. Trudeau's decision making in relation to either matter. The Commissioner therefore found that Mr. Trudeau did not contravene subsection 6(1) of the Act. 

The Commissioner considered whether Mr. Trudeau's relatives' relationship with WE, which created an appearance of a conflict of interest, was captured by the definition of conflict of interest under section 4 of the Act. He determined that without an actual conflict of interest or a clear legislative prohibition against apparent conflicts of interest, he could not conclude that a contravention occurred. 

Although Mr. Trudeau has acknowledged publicly that he should have recused himself because of the appearance of a conflict of interest, there is no requirement to do so under the Act in such circumstances. Section 21 provides that recusal is required only in instances where the public office holder would be in a potential conflict of interest. The Commissioner therefore determined that Mr. Trudeau did not contravene section 21 of the Act. 

In the Morneau II Report, the Commissioner found that Mr. Morneau contravened subsection 6(1), section 7 and section 21 of the Act. 

The Commissioner was satisfied there was no opportunity to further Mr. Morneau's own interests or those of his relatives in the matters under examination. Having examined the nature of his relationship with Mr. Craig Kielburger and the personal and professional interactions between them, he determined they were friends within the meaning of the Act. Consequently, he found that Mr. Morneau had the opportunity to improperly further WE's private interests. 

The Office has traditionally favoured a narrow interpretation of “friend" to include only the public office holder's closest personal friends. The Commissioner believes it is necessary to broaden the scope of the term to capture relationships where personal and professional interactions become intertwined to such an extent that it becomes difficult to draw the line between the two. In such cases, the public office holder's judgment in the exercise of their official powers and duties can reasonably be impaired. 

The friendship between Mr. Morneau and Mr. Craig Kielburger created a potential conflict for Mr. Morneau when called upon to make a decision that would further WE's private interests. Thus, any decision made by Mr. Morneau that provided an opportunity to further WE's private interests was made improperly. The Commissioner therefore found that Mr. Morneau contravened subsection 6(1) of the Act. 

For a contravention of section 7 to occur, the treatment a public office holder gives to a person or organization must be more favourable than the treatment they might give to a similarly situated person or organization, and there must be a prior relationship between the public office holder and the representative. 

The Commissioner found no evidence that Mr. Morneau was directly involved in a departmental decision to propose WE as the administrator of the CSSG. Nor did he appear to have provided instruction or direction to anyone associated with WE's Social Entrepreneurship proposal. However, his ministerial office had an unusually high degree of involvement in past files relating to WE that was also apparent in the matters under examination. The Commissioner was of the view that Mr. Morneau gave WE preferential treatment by permitting his ministerial staff to disproportionately assist it when it sought federal funding. He was of the view that this unfettered access to the Office of the Minister of Finance was based on the identity of WE's representative, Mr. Craig Kielburger. The Commissioner therefore found that Mr. Morneau contravened section 7 of the Act. 

Mr. Morneau should have reasonably known that he was in a potential conflict of interest because of his relationship with Mr. Craig Kielburger when he received WE's Social Entrepreneurship proposal and when he was later advised that WE would likely play an important role in the student relief initiative. The Commissioner found that by having failed to recuse himself from participating in related briefings, discussions and votes, Mr. Morneau contravened section 21 of the Act, as his participation provided an opportunity to improperly further WE's private interests because of his friendship with Mr. Craig Kielburger. 

Barring exceptional circumstances, the Office's target is to conduct examinations within a 12‑month timeframe. Since the Commissioner took office in 2018, 14 reports have been published under the Act. The average time to complete an examination, including examinations prompted by referrals from the Public Sector Integrity Commissioner​, is just over eight months. This average also includes reports on Public Sector Integrity Commissioner referrals where an examination is not warranted. ​​The Office makes it a priority to produce examination reports with due dispatch to ensure that Canadians are well informed in a timely manner of any contravention of the Act, especially when the matter under examination has been made public. To complete investigations within a reasonable timeframe, the Office relies on the cooperation of the subjects of the examinations and other witnesses. 

As of March 31, 2022, the Office was not working on any examinations under the Act.

Examination Case Files

When the Office receives information about a possible contravention of the Act, whether from a Senator or Member of the House of Commons, media reports or complaints from members of the public, it may open a case file. When a case file is opened, the Office conducts an initial review of the matter. Some of these reviews may lead to examinations, which, barring exceptional circumstances, the Office aims to complete within 12 months. When an examination is not found to be warranted, the case file is closed. 

Overall, there was a 28% decrease in the number of case files in 2021-2022. While there was an increase in case files during the second quarter of the fiscal year, which coincided with the electoral period, there was a sharp drop in the number of case files opened during the last two quarters. However, in February and March 2022, the Office received over 1,000 requests from members of the public asking the Commissioner to investigate the participation of Members and ministers in the World Economic Forum. Since the requests did not provide sufficient information to warrant an investigation and they were all related to the same topic, they were counted as a single case file by the Investigations and Legal Services division.  ​

Examination CASE FILES IN 2​021-2022​

Referrals from the Pu​​blic Sector Integrity Commissioner

Matters may be referred to the Commissioner by the Public Sector Integrity Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act. It provides another mechanism for Canadians to request investigations and for the Commissioner to be made aware of possible issues. When such a referral is received, the Commissioner is required, under  section 68 of the Conflict of Interest Act, to issue a public report whether or not an examination is launched. No such referrals were received or reported on in 2021-2022. 

Over​​sight

Information about potential non-compliance can serve as a basis for the Office to reach out to regulatees with advice or direction, or to apply the regimes' enforcement provisions as appropriate. 

To strengthen its oversight of potential non-compliance with the conflict of interest regimes it administers, in May 2022 the Office staffed a new data analyst position in the Communications, Outreach and Planning division. Sources of public information are monitored, particularly in relation to positions that have been evaluated as potentially having a higher risk of conflict of interest. Special attention is paid to outside activities in which reporting public office holders may be engaged and former public office holders' employment after leaving public office.​

PUBLIC COMMUNICATIONS​ 

In support of public education about the regimes that it administers, the Office makes a range of information available on its website, is active on social media, responds to inquiries from the media and members of the public, and delivers presentations to the interested public. Below is a summary of its activities in these areas for 2021-2022. 

The Office monitors the volume of relevant Twitter mentions, news mentions, website activity and mentions during Question Period. In general, high mentions lead to workload increases for the Office. Tracking these trends can help the Office prepare for an influx of public and media inquiries, for example, or become aware of issues that might relate to its work. The Office publishes this data in its quarterly statistical reports. 

We​bsite

The Office continued to maintain its website as an important source of information to help educate and inform regulatees, the media and the public. The number of website visitors increased by 19%, for a total of 52,765 visitors. 

In July 2021, it added to the website a detailed chronology that highlights milestones—dating back almost to Confederation—in the development of Canada's federal conflict of interest regimes and their administration. The chronology is a useful research tool that brings together information from a range of sources and details how the culture of ethics and integrity has been shaped in Canada. 

Soc​​ial Media

The Office's social media presence allows it to be aware of and participate in relevant discussions and provides an additional source of information about the Office and the public registry. 

The Office continued to be active on social media. The total number of followers for @EthicsCanada and @EthiqueCanada grew by 16% (3,596 followers), further increasing the Office's social media reach. It tweeted 159% more times than in the previous year, sending one to two tweets per day. More than 6% of visits to the Office's website were from links on Twitter and the Office's own tweets drove 2% of the traffic. Over half of the Office website's traffic resulted from an Internet search. Although difficult to pinpoint, social media conversations relating to ethics can lead to independent searches of the Office website to verify facts or find more information. 

While the January 2022 survey of public office holders revealed that Twitter is not used as an information source by most public office holders, it is a preferred tool used by the media, who have been identified as key stakeholders of the Office. The Office's tweets can help them report accurately on the Office and its work. When the Office releases a report, its associated tweets often attract attention that may lead to additional inquiries from the public and the media. 

Media and Public In​quiries 

The Office fielded nearly 3,500 information requests received from the media and members of the public by phone, email, post and fax, as well as through direct messages on Twitter. The Communications, Outreach and Planning division has developed procedures and processes to ensure that it provides accurate, timely and useful information to the individuals and groups seeking information. Although the conflict of interest regimes' strict confidentiality provisions mean no information can be provided about individual cases, the Office strives to provide as much information as possible about the rules and their general application. 

The Office was also copied on a number of emails that were not relevant to its mandate. Its practice is to respond only to those that are directly addressed to the Office. Such emails represented 60% of total correspondence received in 2021-2022. 

The media can help the Office provide accurate information to the public about the conflict of interest regimes that it administers. In 2021-2022, it received 47% fewer requests from the media compared to the previous year. Many of those requests sought information about the Trudeau III and Morneau II reports and were received in the months preceding their May 2021 release. Direct inquiries about the status of a current case file or public office holder constituted 80% of media requests. Only 20% related to general inquiries about the role and mandate of the Office. Journalists have demonstrated an increased understanding of the regimes, which may have resulted in fewer requests for information about general topics. The Office met its four-hour service standard for responding to media inquiries in 100% of cases. 

The Office also took a proactive approach in a particular case. It had received several media inquiries about the compliance of former public office holder Dominic Barton with the Act's post-employment rules, but because of confidentiality requirements, it could not provide any information. The Office later received consent from Mr. Barton to share information about the matter and reached out to the journalists who had requested information about it. This move contributed to transparency and helped provide Canadians with information that would allow them to be better informed. 

The Office started categorizing by subject the information requests it receives, to see if any trends can be observed. For instance, does an increase in media inquiries about a particular topic prompt more requests about it from members of the public and from public office holders seeking advice? This kind of information helps the Office adapt its education and outreach activities as appropriate. For example, there were several inquiries about regulatees' general obligations, gifts, post-employment and outside activities, all of which align with the categories the Office tracks when it provides advice to regulatees. The Office consequently tweeted about these subjects to help educate the public. 

The data also revealed that 15% of media requests received in the past year related to ongoing public investigations while 65% were direct inquiries about a regulatee's compliance. Because of confidentiality restrictions, the Office cannot provide any information about individual regulatees other than what is already in the public registry. The Office provides additional context about the administration of the Act the Code when possible. 

Just over a third of public inquiries were complaints about various subjects. The Office generally cannot act on these complaints because they are either outside of its mandate or there are no reasonable grounds to believe that a contravention has occurred based upon the information received in the query. When relevant, complainants are asked to fill out an investigation request form. If they submit a completed form, the Office notifies them that their information will be reviewed. 

Over 1,000 of the public and media inquiries received by the Office during the year were from members of the public asking the Commissioner to investigate the involvement of Canadian parliamentarians in the World Economic Forum. These requests were received in February and March 2022. The Communications, Outreach and Planning division responded on behalf of the Office to each one by explaining the mandate and role of the Office and providing information about the investigation process. The responses were tracked in its public inquiry statistics. 

In the first quarter of the fiscal year, the Office achieved its service standard for responding to public inquiries within 10 days at 80%. Although this met the threshold set by the Office, an analysis of the response process revealed there were some efficiencies to be gained and it was changed slightly. The Office was subsequently able to achieve its service standard at higher rates, ending the year with an 89% achievement of its 10-day service standard.

COLLABO​RATION AND BEST PRACTICES

Thanks in part to the technology that makes it possible to have productive and effective meetings virtually,  the Office continued to maintain and strengthen connections with officials and organizations in Canada and other countries in 2021-2022. 

Domestic O​utreach 

The Commissioner participated in the annual meeting of the Canadian Conflict of Interest Network (CCOIN) in September 2021 and in its semi-annual meeting in March 2022. CCOIN is made up of federal, provincial and territorial conflict of interest commissioners. The Office coordinates information sharing within the network, gathering and disseminating information and materials acquired by or developed in various Canadian jurisdictions. 

Several Canadian universities asked the Office to provide an overview of the Commissioner's role and mandate to give students an opportunity to gain a firsthand understanding of Canada's federal conflict of interest regimes. The Commissioner delivered a presentation at Carleton University and another at York University alongside Information Commissioner Caroline Maynard. 

In July 2021, the Commissioner participated in Quebec Ethics Commissioner Ariane Mignolet's podcast with Senate Ethics Officer Pierre Legault. They discussed conflict of interest and ethics jurisdictions across Canada and the benefits of belonging to networks of ethics practitioners. 

In February 2022, the Office submitted com​ments on the draft update of the Lobbyists' Code of Conduct during a consultation process initiated by Commissioner of Lobbying Nancy Bélanger. Participating in this process aligned with the principles of the Memorandum of Understanding signed by the two commissioners in March 2018. 

The Commissioner met privately with other agents of Parliament to discuss common issues and concerns, and Office employees liaised with their counterparts in those agents' offices. 

International Outr​each 

The Office always considers the value added to its mandate when it agrees to participate in international events. Sharing best practices, learning about the ways conflict of interest rules are applied and listening to the public discourse around ethics issues in other jurisdictions are part of ongoing developmental activities for members of the Office. As the field of public ethics continues to change and grow, keeping abreast of ongoing developments can help inform the Office's work. 

The Office remains an active member of the Réseau francophone d'éthique et de déontologie parlementaires (RFEDP) [link in French only] within the Organisation internationale de la Francophonie. The RFEDP fosters the sharing of best practices to enhance expertise and help the parliaments of Francophonie member countries adopt ethics principles and conflict of interest rules. In 2021-2022, the Office contributed to two RFEDP working groups focused on training and best practices. In November, the Commissioner and several other members of the Office participated in the RFEDP's two-day annual general meeting and the Director of Advisory and Compliance was nominated to its Bureau. 

The Office also continues to be an active member of the Council on Governmental Ethics Laws (COGEL), a U.S.-based international not-for-profit organization of government ethics practitioners in which other Canadian conflict of interest and integrity offices also participate. In December, the Commissioner and Office representatives attended COGEL's virtual annual conference. The Director of Communications, Outreach and Planning is a member of the program planning committee for COGEL's 2022 conference, an in-person event that will be held in Montreal in December. 

International outreach activities in 2021-2022 included participation by the Commissioner and other senior Office representatives in bilateral meetings with international counterparts to discuss Canada's ethics regimes and share best practices, and in other events. The Office also responded to several requests for information from or on behalf of international organizations. 

In September 2021, communications methods and tools were discussed with France's Haute Autorité pour la Transparence de la vie publique. 

In October, the Office met with the Public Sector Directorate of the Organisation for Economic Co-operation and Development (OECD) to answer its questions about best practices that could be implemented by the Office of the Commissioner for Standards in Public Life in Malta. 

In November, the Commissioner participated in a panel at the one-day conference on ethical standards in government organized by the United Kingdom's Institute of Government. The panel was entitled “What can the UK learn from how other governments uphold standards?" Commissioner Dion participated alongside the Director of Policy Transparency International UK and the Commissioner for Standards at the Northern Ireland Assembly. The invitation to this event resulted from the Commissioner's March 2021 appearance before the United Kingdom's independent Committee on Standards in Public Life to discuss how Canada's federal ethics regimes work. 

That same month, the Office sent comments on the Third Resolution for the 9^th Session of the Conference of the States Parties to the United Nations Convention Against Corruption through Global Affairs Canada. The resolution, “Enhancing the use of beneficial ownership information to facilitate the identification, recovery and return of proceeds of crime," seeks to address asset recovery. 

In December, the Office was approached by the Treasury Board of Canada to provide input into the OECD's integrity indicators. Its input related to reporting requirements of appointed and elected public officials and general information about Canada's federal conflict of interest regimes. This project was part of the OECD Pub​lic Integrity Indicators Portal, which will compile data to provide an accurate picture of the state of public integrity among OECD countries. The Office will monitor the portal, which will provide access to comparative data for benchmarking purposes. 

In February 2022, it shared information about Canada's public integrity framework with representatives of Israel's Ministry of Justice. 

Finally, in March, Office representatives attended the OECD's Global Anti-Corruption and Integrity Forum. The theme was “Renew governance, business, finance, sustainability, development aid, taxation and more, with integrity." 

When approached, the Office is pleased to share best practices relating to the administration of the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. In March 2022, the Commissioner met with the Honourable Stéphane Dion, Ambassador to Germany and Special Envoy to the European Union, to discuss sharing best practices with the Office's counterparts in Armenia. Later that month, it was contacted by the Embassy of Mongolia and agreed to meet with its counterparts from Mongolia. Future meetings may take place during the next fiscal year.

The Office's accomplishments result from the hard work, dedication and resilience of its employees in implementing the Commissioner's vision, with the support of a sound internal management framework. 

OUR PEO​​PLE 

To ensure the Office has the human resources it needs to fulfill its vision and achieve its mission, two staffing processes were completed or initiated in 2021-2022. 

The Office continued to operate primarily in a telework environment. It developed a new telework policy that will take effect in the new fiscal year. Under it, the Office will adopt a hybrid model where employees may choose, in consultation with their director, to work from home some or all of the time, while continuing to ensure the Office delivers on its mandate. The flexibility this approach gives employees can help them achieve a better work-life balance and reduce stress, thereby helping the Office retain and attract talent. In general, employees appreciate being able to telework and this contributes to a positive workplace. The Office is also planning to reduce its physical space requirements as fewer employees will need to be accommodated on-site. 

To continue to address matters of importance across the federal public sector and elsewhere, the Office has created two cross-divisional working groups. One is focused on Equity, Diversity and Inclusion and aims to apply the concepts that harness the strengths of a diverse workforce. The other is focused on Learning and Development and aims to equip employees with the tools and skills that are required to efficiently fulfill the Office's mandate. 

The Office has started taking steps to implement Bill C-81, An Act to ensure a barrier-free Canada. This legislation will benefit all Canadians, and especially persons with disabilities, by preventing barriers in areas like information and communications technologies. 

The Office refined and started implementing a comprehensive plan to strengthen and expand internal communications. Strong internal communications can build employee engagement. They can help ensure employees' well-being by contributing to their mental health, motivation and happiness. And they can drive operational excellence, by ensuring all employees have the information they need to do their jobs, helping them see the big picture and how their work supports it, and making them feel invested in the organization. Internal communications are also especially important in a telework or hybrid environment. 

In February 2022, the Office launched a new intranet, a collaborative hub that enables employees to easily access the internal information and resources they need to do their jobs effectively and eliminate potential duplication of effort. It reflects a key focus area of the Office's strategic plan: establishing efficient, accessible and user-friendly information and data management systems. It also contributes to the goal of ensuring an engaged, collaborative, healthy, inclusive and diverse workforce. The Office updated its employee orientation guide to better support onboarding. It created a new tool to improve collaboration among employees by providing ideas and approaches for handling new types of cases that may not fall within pre-set processes, suggesting questions that employees should ask themselves to help guide them and providing a list of internal contacts, categorized by file, to help them find the answers they need. The Office also linked employee awards to specific competencies by developing an updated awards and recognition program that aligns with the Office's Code of Values and Standards of Conduct. 

To ensure the Office's policy framework reflects current realities, the Office developed and implemented a Policy on COVID-19 Vaccination and a Work Place Harassment and Violence Prevention Policy. It also published a Pay Equity Act notice signalling its intent to post a pay equity plan by the legislated deadline of August 31, 2024, and to update it. 

The Workplace Harassment and Violence Prevention Policy, which took effect in May 2021, was established to meet the requirements of the Parliamentary Employment and Staff Relations Act regarding the Canada Labour Code, Part II, and its Work Place Harassment and Violence Prevention Regulations. It applies to all employees of the Office, as well as to every person granted access to the work place. This includes the Office's premises at 66 Slater Street in Ottawa, or any location or any event related to work activities, including while working remotely/from home in accordance with an employer-approved telework arrangement. As required by the policy, the Office conducted an assessment of internal and external risk factors to target any hazards specific to the Office that could contribute to harassment and violence in the work place. While the assessment showed that many measures were already in place to mitigate identified risks, the Office developed some additional measures. The Office held a mandatory information session on the policy for all employees, made related resources available on its intranet and required all employees and managers to take relevant training. Going forward, all new employees must complete training on workplace harassment and violence prevention within three months of their start date. ​

Our c​​hallenges

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