Code of Conduct

Table of contents

Introduction

The Values and Ethics Code for the Public Sector (Public Sector Code) describes the values and expected behaviours that guide public servants in all aspects of their professional duties as well as any off-duty conduct that may impact their organization or the federal government.

The Public Sector Code requires that each deputy head establish a Code of Conduct for their organization. The Canadian Northern Economic Development Agency (CanNor) has accordingly developed this Code of Conduct in the context of CanNor's Northern mandate and operating environment. This Code provides a framework of values and behaviours that guide us in all our activities as we work to ensure that the North remains vibrant and strong. By committing to this Code, you strengthen the ethical culture of CanNor, the public sector and contribute to public confidence in the integrity of all public institutions.

Scope

This Code applies to all persons employed at CanNor. This comprises indeterminate or term employees (full-time and part-time), including employees on leave without pay, a person in casual status, a student hired under a Public Service Commission student program, a seasonal or part-time worker, or a person on secondment or Interchange Canada assignment with CanNor.

Consequences of non-compliance

Adherence to this Code, the Public Sector Code and the Directive on Conflict of Interest is a condition of employment for all persons employed at CanNor. It is your responsibility to become familiar with the contents of this Code, to abide by its requirements and to seek guidance if you are unclear about the appropriate action to take. A breach of the Code may result in disciplinary measures, up to and including termination of employment. Your employment contract with CanNor applies outside of working hours and when you are on leave with or without pay.

A few words on values and ethics for CanNor employees in the North

Most of CanNor's employees live and work in one of the three Northern territories. For them, and for those visiting the North, adhering to this Code may require more mindful attentiveness given the close-knit nature of these communities.

In light of these considerations, adhering to this Code and the Public Sector Code may require more heightened awareness and mindfulness when applied in a northern context.

Chapter 1: Statement of values and expected behaviours

Respect for Democracy

The system of Canadian parliamentary democracy and its institutions are fundamental to serving the public interest. Public servants recognize that elected officials are accountable to Parliament, and ultimately to the Canadian people, and that a non-partisan public sector is essential to our democratic system.

Expected behaviours

Uphold the Canadian parliamentary democracy and its institutions by:

  1. Respecting the rule of law and carrying out your duties in accordance with legislation, policies and directives in a non-partisan and impartial manner.
    • Your actions, recommendations and decisions are objective, based on sound judgement, consistent with the federal legislative and policy framework, respect the letter and spirit of the law and preserve public confidence in the integrity of the public service.
  2. Loyally carrying out the lawful decisions of your leaders and supporting Ministers in their accountability to Parliament and Canadians.
    • You have a duty of loyalty to the Government of Canada. This includes a duty to refrain from publicly criticizing the government, its policies, priorities, programs or officials and a duty to ensure that your actions, including off-duty conduct, do not harm the reputation of the Agency or the government and preserve public confidence in the integrity of the public service. For additional information, see "More on: Duty of Loyalty".
  3. Providing decision-makers with all the data, analysis and advice they need to make fully informed decisions, and always striving to be open, candid, honest and impartial in order to present a complete and balanced perspective.
    • You have developed expertise that others depend upon. You gather and consolidate all of the necessary information and data, identify and thoroughly analyze key factors and prepare complete, accurate and unbiased information, analysis and advice. You don't downplay or over-emphasize risks or benefits, regardless of your personal opinion.

Respect for people

Treating all people with respect, dignity and fairness is fundamental to our relationship with the Canadian public and contributes to a safe and healthy work environment that promotes engagement, openness and transparency. The diversity of our people and the ideas they generate are the source of our innovation.

Expected behaviours

Respect human dignity and the value of every person by:

  1. Treating every person with respect and fairness.
    • You are courteous, transparent, honest, objective and unbiased with everyone with whom you interact during the course of your workday.
    • You are respectful and fair in potentially difficult workplace situations such as when differences of opinion arise.
  2. Valuing diversity and the benefit of combining the unique qualities and strengths inherent in a diverse workplace.
    • You welcome backgrounds and experiences that are different from your own, and are open to new ideas and approaches. You respect cultural differences and strive to act and communicate in a culturally competent manner with colleagues, stakeholders and clients. In particular, you demonstrate sensitivity towards the values, socio-cultural traditions, and history of Indigenous peoples, and embrace the principles of reconciliation. You actively engage in learning and unlearning, and listen to Indigenous voices to understand different ways of knowing and doing.
    • As a manager, you are aware of modern treaty obligations respecting the employment of Indigenous peoples. You are knowledgeable about the objectives and commitments of CanNor's Inuit Employment Plan, and proactively contribute to meeting its goals.
  3. Helping to create and maintain safe and healthy workplaces that are free from harassment and discrimination.
    • You follow health and safety regulations and policy, and report any issues to your manager.
    • You do not engage in or ignore bullying, offensive behaviour, harassment or discrimination. For information on how to deal with these issues, visit CanNor's intranetFootnote roman numeral 1.
  4. Working together in a spirit of openness, honesty and transparency that encourages engagement, collaboration, partnerships and respectful communication.
    • You treat difficult work situations with tact and objectivity, without assigning blame, and receive the same treatment in return. You manage conflict constructively. You feel at ease in sharing ideas with your colleagues, knowing that your input will be valued. You feel comfortable and safe in discussing personal matters such as work life balance with your manager, knowing that you will be listened to attentively and in good faith.
    • As a supervisor, you create a safe place for employees, keep them informed, welcome their honest feedback, set clear expectations and communicate openly and effectively.

Integrity

Integrity is the cornerstone of good governance and democracy. By upholding the highest ethical standards, public servants conserve and enhance public confidence in the honesty, fairness and impartiality of the federal public sector.

Expected behaviours
  1. Acting at all times with integrity and in a manner that will bear the closest public scrutiny, an obligation that may not be fully satisfied by simply acting within the law.
    • You put the common good ahead of any personal interest. You are honest, accountable and authentic.
    • Your work meets both the letter and spirit of the law, and you believe that how you achieve a goal is as important as the goal itself. If you are in doubt about the "rightness" of doing something, you don't do it. You ask yourself how you would feel if your actions were reported in the news.
    • You bring ethical concerns to the attention of your manager or to other appropriate sources within CanNor. You honour professional commitments and ensure that your behaviour, both at and away from work, reflects positively on CanNor and on the public sector as a whole.
  2. Never using your official role to inappropriately obtain advantage for yourself or disadvantage others.
    • You don't use your title or position to obtain any private or personal advantage for yourself or your family and friends.
  3. Taking all possible steps to prevent and resolve any real, apparent or potential conflicts of interest between your official responsibilities and your private affairs in favour of the public interest.
    • Avoiding, preventing or eliminating conflicts of interest is one of the principal means of maintaining public trust and confidence in the impartiality and integrity of the public service.
    • Being familiar with this Code will help you to avoid conflicts of interest.
    • For employees working in the North, where a separation between public and private lives is more difficult to maintain and public servants are very visible in their communities, perceived conflicts of interest may be more frequent.

See Chapters 3 & 4 of this Code for more information on Conflict of Interest.

Stewardship

Federal public servants are entrusted and accountable to use and care for public resources responsibly, for both the short term and long term.

Expected behaviours

Use resources responsibly by:

  1. Effectively and efficiently managing public money, property and resources.
    • Resources such as people, time and supplies are used effectively and efficiently to meet clearly stated and understood goals.
    • If you are in a position with responsibility for procurement, you respect modern treaty obligations respecting government contracts and the federal government's indigenous procurement policy.
    • If you are in a position that manages public money, you exercise due diligence and follow the rules set out in the Financial Administration Act and related Agency policies.
    • You use government property such as office supplies and equipment, electronic devices and ID cards only for official purposes, unless limited personal use is authorized (e.g., GoC electronic networks). Limited private use is: conducted on personal time; is not for financial gain; does not result in additional cost for the Agency or impose a storage or bandwidth burden; and, does not affect your productivity or that of your colleagues. Remember that unauthorized use of electronic networks can always be traced back to the offender, and may result in disciplinary action.
    • You adhere to the Directive on Service and Digital and the Guideline on Acceptable Network and Device Use.
  2. Considering the present and long-term effects that your actions have on people and the environment.
    • If you have an opportunity to influence policies, programs and services, you consider sustainable development principles.
    • You use good environmental practices on a day-to-day basis, (e.g., reducing paper waste; using the office recycling program where possible).
  3. Acquiring, preserving and sharing knowledge and information.
    • You respect confidentiality and use information acquired from consultative processes in a transparent and accurate way.
    • You share personal or confidential information only on a need-to-know basis.
    • You ensure that records of business value are properly classified and saved.
    • When working remotely, you follow the Agency's procedures for secure transportation or transmission between locations, and you are careful to prevent unauthorized access to government information by others who may be at your remote work location.

Excellence

Excellence in the design and delivery of public sector policy, programs and services is beneficial to every aspect of Canadian public life. Engagement, consultation, collaboration, effective teamwork and professional development are all essential to a high-performing organization.

Expected behaviours

Demonstrate professional excellence by:

  1. Providing fair, timely, efficient and effective services that respect Canada's official languages.
    • You respect the diversity and traditions of the North when delivering services.
    • You manage your work to achieve the best possible results.
    • You respect the use of Indigenous languages in our workplaces.
    • The Agency respects English and French as Canada's two official languages and is mindful of its commitments under the Official Languages Act.
  2. Continually improving the quality of policies, programs and services you provide.
    • You take pride in the quality of your work and look for ways to improve.
    • You readily share ideas for different, improved ways of doing things and are open to the ideas of others.
  3. Fostering a work environment that promotes teamwork, learning and innovation.
    • You engage in continuous learning.
    • Supervisors work with employees to ensure that learning plans are meaningful.
    • Managers encourage and promote opportunities for teamwork collaboration and intelligent risk management.
    • Managers actively evaluate the health of their teams and take steps to improve team cohesiveness, morale and motivation when required.

More on: Duty of loyalty

The duty of loyalty is a cornerstone of public service. It is a commitment to uphold the interests of the federal government and the Canadian public, and it encompasses several key aspects:

  1. Upholding the Constitution and Laws: Public servants have a duty to uphold the constitution and laws of the country. This includes ensuring that their actions are in accordance with legal and regulatory frameworks and respecting the rights and freedoms of citizens.
  2. Serving the Public Interest: The duty of loyalty means putting the public interest first. Public servants must make decisions and take actions that benefit the public, even if it means setting aside personal interests or opinions.
  3. Maintaining Confidentiality: Public servants often have access to sensitive information. The duty of loyalty requires them to protect this information and not disclose it without proper authorization.
  4. Political Neutrality: Public servants must carry out their duties in a politically neutral manner. They should not let their personal political beliefs influence their work, and they must serve the government of the day, regardless of its political affiliation.
  5. Respect for Democracy: The duty of loyalty includes respect for democratic processes and institutions. Public servants must support the democratic process, including free and fair elections, and respect the decisions made by elected officials.
  6. Integrity and Honesty: Public servants must act with integrity and honesty. They should not engage in fraudulent or corrupt practices, and they must be truthful in their dealings with the public and their colleagues.
  7. Accountability: Public servants are accountable for their actions and decisions. They must be willing to explain and justify their actions, and they must accept responsibility for any mistakes or failures.

An employee's obligation to avoid publicly criticizing their employer is a principle that is found in both the private and public sector. In the context of the public sector, this principle stipulates that public servants should refrain from making public statements that could undermine the reputation of the Government of Canada. This includes publicly criticizing the government's priorities, policies, programs or officials. It is based on the premise that such actions can erode public trust in public servants' ability to serve the lawfully elected Government.

If a public servant believes that the government is engaged in illegal acts or that its policies jeopardize life, health or safety, they should engage in the process for disclosure of wrongdoing. At CanNor, wrongdoings of the Agency or other federal organizations can be disclosed through your manager, the Senior Officer for Disclosure for CanNor, or the Public Sector Integrity Commissioner.

To avoid failing in your duty of loyalty, remember that any public comments you make, including those made on social media networks, should be factual, objective and impartial. You should refrain from publicly commenting on your personal differences or concerns with the Government of Canada or CanNor's positions and decisions. You should ensure that all public comments, opinions or actions, including off-duty conduct, preserve and enhance public confidence in the integrity and impartiality of the public service.

More on: Off-duty conduct

Off-duty conduct, including social media activity, is a private matter, unless and until it negatively affects your performance as a CanNor employee, the image of the Agency or the public service, or the public's confidence in the administration of government.

You should avoid off-duty conduct that:

  • Is or could be harmful to the Agency's reputation.
  • Impacts your ability to perform your duties in a satisfactory manner.
  • Leads to other employees refusing, being reluctant or unable to work with you.
  • Constitutes a breach of the Criminal Code, a federal law, or any other legislation that may have a direct impact on your duties, whether or not you are actually charged with an offence.
  • Makes it difficult for the Agency to manage its operations efficiently or to direct its workforce.

You are expected to tell your manager about off-duty conduct that may be problematic as soon as possible. If you're not sure whether your conduct was problematic, you should ask for advice from your manager or HR. Don't ignore the situation.

More on: Use of social media

Material in this section has been adapted from the Treasury Board Secretariat's "Guidance for Public Servants on their Personal Use of Social Media". Please consult the Guidance for comprehensive information.

Social media and other online platforms are, for the most part, permanent records of what has been said or done that may be copied among platforms without context. Regardless of your privacy settings, don't assume that your online content is protected from being viewed or shared without your consent. You also should remember that anonymous posts may be traced back to you or to your role as a public servant.

As a public servant with a duty of loyalty, there are factors that could elevate the risk that your social media activities might impact your employment. They include, but are not limited to, the following:

  • The classification, level and type of position you are in. Think not only about your current position, but also positions you might aspire to in the future.
  • The subject matter of your content and its relationship to your current or future work, as well as the work of CanNor.
  • The extent to which you are visible to the public in your role and identifiable as an employee of the Agency or the public service. The more visible your position, the more weight is likely to be given to what you post.
  • Your visibility on social media. Your influence on public opinion may rise as the number of your followers increases.

Here are some things to think about before you post.

  • Is this post an expression of opinion, either positive or negative, that would result in a reasonable person questioning my ability to perform my duties in an impartial and unbiased manner?
  • Does the post contain information about clients that is not in the public domain?
  • What is the quality of the language I'm using e.g., is there disparaging or offensive language in the post?
  • Am I using a hashtag or sharing, liking or tagging posts that may connect to content that is objectional, offensive or illegal? This could give the impression that I agree with the content, which would be a contravention of the Code, and could affect relationships with my clients and co-workers.
  • Do I have permission to post comments/pictures of my co-workers?
  • Am I using social media to promote my personal business? Is it possible that my posts could cast doubt on my ability to perform my duties in a fair, transparent and impartial manner?

In summary, when using social media, it is essential to remember your responsibilities under this Code, and to exercise sound judgment and common sense to ensure that personal and professional use does not compromise the Agency's or the Government of Canada's reputation, its protected information, or your work relationships with colleagues, stakeholders and clients.

Use of personal social media accounts on Government of Canada electronic networks must be limited and conducted on personal time.

Chapter 2: Avenues of resolution

It is impossible for this Code to cover every ethical issue that you might face. If you are in doubt about what to do, discuss with your immediate supervisor or CanNor's HR team. Don't ignore your instinct that something might be wrong.

Other resources include a more senior manager, your union representative, the Senior Officers for Values and Ethics and for Conflict of Interest, the Agency's Informal Conflict Management ServicesFootnote roman numeral 2 or our OmbudsFootnote roman numeral 3.

If you have information that could indicate a serious breach of this Code by CanNor employees or other government employees/organizations, you can bring the matter, in confidence and without fear of reprisal, to the attention of your immediate supervisor, CanNor's Senior Officer for Disclosure or to the Office of the Public Sector Integrity Commissioner.

Members of the public who have reason to believe that a person employed at CanNor has not acted in accordance with this Code can bring the matter to CanNor's Senior Officer for Disclosure or to the Office of the Public Sector Integrity Commissioner.

Chapter 3: Conflict of interest during public service employment

3.1 Introduction

The requirements set out in this chapter are grounded in and serve to uphold the values contained in this Code. Adherence to these requirements is a condition of your employment.

It is impossible to foresee every conflict of interest situation. When in doubt, refer to this Code, or ask for guidance from your manager, HR or CanNor's Senior Officer for Conflict of Interest.

3.2 Definitions

Conflict of Interest (CoI): A situation in which the person employed has private interests or activities that could improperly influence the performance of their official duties and responsibilities or in which the person employed uses their office for personal gain.

There is also a "Conflict of Duties (CoD)" which is a conflict that occurs, not because of the private interests of the person employed but as a result of one or more concurrent and competing official responsibilities e.g., a person employed who is also appointed to a board of directors as part of their official duties. Reporting requirements for a CoD are the same as for a CoI.

A real CoI or CoD exists at the present time; an apparent CoI or CoD is a situation that could be perceived as a CoI or CoD by a reasonable observer, whether or not it is the case; and, a potential CoI or CoD could reasonably be foreseen to happen in the future.

3.3 General responsibilities

  1. Take all possible steps to identify, prevent, report, and resolve any real, apparent or potential conflict of interest. Preventing and avoiding these situations is the primary method by which you, as an employee of CanNor, can maintain public confidence in the impartiality and integrity of the public service.
  2. Refrain from having private interests or engaging in outside employment or activities that may subject you to demands incompatible with your official duties, or that could be seen to impair your ability to perform your duties and responsibilities in an objective and impartial manner.
  3. Do not knowingly take advantage of, or benefit from, information that is obtained in the course of your work and that is not available to the public.
  4. Refrain from using your position as leverage to influence or gain personal benefit for yourself, family members, friends or colleagues.
  5. Refrain from undertaking any financial arrangements with outside entities or individuals where there is a risk of conflict of interest. If in doubt, consult with your manager. Financial arrangements include procuring goods, contracting for services or administering grants and contributions or transfer payments.
  6. Refrain from the direct or indirect use of, or allowing the direct or indirect use of, government property of any kind, including property leased to the government, for anything other than officially approved activities.
  7. Do not assist private entities or persons in their dealings with the government where this would result in preferential treatment.
  8. Do not interfere in the dealings of private entities or persons with the government in order to inappropriately influence the outcome.
  9. Ensure that any real, apparent or potential conflict that arises between private interests or activities and official responsibilities is resolved in the public interest.

3.4 Reporting requirements and documentation

If you are found to be in a conflict of interest or conflict of duties situation which you have not reported, you may be in contravention of this Code and could be subject to discipline. Being attentive to the requirements outlined below will safeguard you from this possibility. If you're unsure about the need to file a report, contact HR.

If an assessment of your disclosure indicates that there is a conflict of interest, please remember that your integrity and your ability to be impartial and objective are not being questioned. A finding of conflict of interest does not mean that you have done anything wrong.

Reporting requirements

You are required to review your obligations under the Code and possibly make a formal disclosure as promptly as possible and within 60 days:

  • Of your initial appointment or any subsequent appointment (including actings), transfer or deployment, or any other major change in your official duties. Note: This is required even if there is no possibility of conflict of interest. If a NIL report is being filed, no assessment tool is required.
  • Every time a major change occurs in your personal affairs.
  • If you think that you might be in a conflict of interest as a result of any of the situations discussed later in this chapter (e.g., outside activities or employment; preferential treatment).

Reporting requirements apply even if you are on leave without pay.

Documentation

Except for NIL reports, each formal conflict of interest disclosure requires the following two forms:

  1. CanNor's Conflict of Interest Disclosure ReportFootnote roman numeral 4.
  2. The Assessment ToolFootnote roman numeral 5 relevant to the situation being declared. There are assessment tools for:
    • Financial Assets and Liabilities;
    • Outside Employment or Activities, including Political Activities;
    • Outside Employment or Activities: Board of directors;
    • Gifts, Hospitality or Other Benefits; and,
    • Preferential Treatment.

NIL reports require only the conflict of interest disclosure form.

Filing these two documents will normally be sufficient to meet the requirements of this Code. Occasionally, additional compliance measures such as those discussed later in this chapter may be required.

See Appendix D for the conflict of interest disclosure process and processing standards.

3.5 Additional guidance on conflict of interest related to:

  • Assets, liabilities and financial mitigation
  • Outside employment or activities
  • Political activities
  • Gifts, hospitality and other benefits
  • Fundraising
  • Avoidance of preferential treatment due to personal relationships outside or within the workplace

3.5.1 Assets, liabilities and financial mitigation

If you have reportable assets, you are required to file disclosure documents within 60 days of each change in your official duties. See Appendix C for a list of reportable and exempt assets and liabilities.

Details on the requirements for preventing and resolving financial conflicts of interest (financial mitigation) are set out in the Directive on Conflict of Interest, Appendix B. Examples include divestment, blind trust agreements and asset-freezing arrangements.

3.5.2 Outside employment or activities

Outside employment or activities that may pose a risk of a conflict of interest must be reported, ideally before the employment is accepted or the activity is begun. You may be required to refuse, terminate or modify the outside employment or activity if it is determined that a conflict exists. If you are unsure whether you should file a disclosure report, get advice from your manager or HR.

Special attention is required when the outside employment or activity:

  • Is with an entity that has dealings with CanNor;
  • Is linked to your official duties at CanNor; or
  • Involves an organization applying for or receiving funding from CanNor.

You should also disclose any employment or activities which could be seen as a lever to obtain special treatment from colleagues, your manager or clients (e.g., your part-time employment allows you to offer perks to others, which may be seen as creating an obligation of reciprocation).

You are not permitted to use contacts developed through your work to seek, acquire or conduct outside employment.

Disclosure is required if you currently sit on or intend to join a board of directors of an organization, corporation or association outside of the Government of Canada, if this activity might give rise to a conflict of interest. You must also be vigilant to ensure that a conflict does not arise through activities such as representing an organization in dealings with or obtaining funding from the Government of Canada.

You must disclose any benefit or income received as a result of a contract with the Government of Canada.

3.5.3 Political activities

Under Part 7 of the Public Service Employment Act, you have the right to engage in political activities at the federal, provincial, territorial or municipal level, so long as they do not impair, or are perceived as impairing, your ability to perform your duties in a politically impartial way. "Political activities" are defined as:

  • Any activity in support of, within, or in opposition to, a political party;
  • Carrying on any activity in support of or in opposition to a candidate before or during an election period; or,
  • Seeking nomination as or being a candidate in an election before or during the election period.

Non-candidacy political activities include fundraising for a candidate or political party, attending rallies or other political events, and placing a sign on your lawn.

The following factors should be considered prior to engaging in a non-candidacy political activity:

  • The nature of your current public service duties at CanNor;
  • The level and visibility of your position;
  • The nature of the political activity; and
  • Your personal visibility.

The Public Service Commission's Political Activities Self-Assessment Tool can assist in making an informed decision about whether to engage in a non-candidacy political activity. The Self-Assessment Tool is simply a guide. You may also wish to discuss specific circumstances with your supervisor or CanNor's designated political activities representative.

Candidacy political activities involve seeking nomination as or being a candidate. You are required to seek and obtain prior permission from the Public Service Commission, in accordance with Part 7 of the Public Service Employment Act. Contact CanNor's designated political activities representative for more information about the process.

More information can be found on the Public Service Commission's Political Activities website.

If you wish to engage in a political activity not covered by Part 7 of the Public Service Employment Act, you are required to disclose the proposed activity before starting.

3.5.4 Gifts, hospitality and other benefits

Accepting gifts, hospitality and other benefits is fine if they:

  • Are infrequent;
  • Of minimal value;
  • Are within the normal standards of courtesy or protocol;
  • Flow from activities related to official duties; and
  • Do not compromise or appear to compromise your integrity or that of CanNor.

You are expected to use good judgement and to refuse any gifts, hospitality or other benefits that may have a real, apparent or potential influence on your objectivity in carrying out your official duties and responsibilities, or that may place you under obligation to the donor. This includes gifts such as free or discounted admission to sporting and cultural events, travel or conferences.

Where it is impossible to decline gifts, hospitality or other benefits that do not meet the criteria set out above, or where it is believed that there is sufficient benefit to the organization to warrant acceptance, prompt disclosure is required.

Gifts, hospitality and benefits from Indigenous communities

CanNor is mindful of Indigenous traditions and culture in relation to gifts and hospitality. Gifting is a sign of gratitude or respect, and often demonstrates appreciations of one's knowledge and effort in reaching common goals. You must balance the possibility of causing offence by refusing a gift, or creating a conflict of interest by accepting it.

If you are offered a gift that is not of minimal value (e.g., paintings, blankets, carvings) and it is not appropriate to refuse the gift due to cultural sensitivities, you may accept the gift on behalf of CanNor. You should promptly advise your supervisor and submit a Disclosure Report. If it is determined that it would be inappropriate for you to keep the gift, you must follow-up with the presenter, thank them, explain CanNor's Code of Conduct requirements and the course of action taken. For example, the gift could be displayed in a boardroom with a plaque indicating the provenance.

3.5.5 Solicitation for the purpose of fundraising

You may not solicit gifts, hospitality, other benefits or transfers of economic value from external organizations or individuals while representing yourself as a CanNor employee.

If an outside individual or entity with whom CanNor has past, present or potential official dealings offers a benefit to the organization, such as funding for an event or a donation of equipment, you must obtain the written consent of the Senior Officer for Conflict of Interest prior to accepting.

Fundraising for personal causes within the workplace

This section applies to fundraising conducted by a single employee where donations will benefit only that employee or their family or friends. It does not apply to fundraising for the Government of Canada Workplace Charitable Campaign or other officially sanctioned events.

Fundraising for personal, not-for-profit causes is permitted, provided the activity does not involve active solicitation (e.g., going from desk to desk, making an announcement at a team meeting or in the office). Active solicitation can put undue pressure on co-workers, especially if they perceive that you could affect them professionally or personally, and make them feel obliged to donate, even if they do not support the cause or can't afford the donation. Items can be placed in a common area with a description of the purpose, contact information and an envelope to collect funds.

You should not solicit funds from persons or entities with whom you have a CanNor-related business relationship.

Using government resources such as email, printers or time, is not permitted.

3.5.6 Avoidance of preferential treatment

Persons employed at CanNor are responsible for demonstrating objectivity and impartiality in all aspects of their duties and responsibilities.

This means that you are not allowed to give preferential treatment or advantages to family, friends or any other person or entity. You also are not to disadvantage any persons or entities dealing with the government because of personal antagonism or bias. Examples of preferential treatment include: providing information that is not publicly available: giving special attention to a client to the detriment of others; and, consistently giving the most interesting assignments to one person when other employees are equally qualified and available.

Personal and family relationships in the workplace

All persons employed are entitled to be treated fairly and equitably with respect to employment opportunities, work assignments, training opportunities and professional development. Personal attachments between CanNor employees must not result in preferential treatment.

CanNor programs and services are delivered in small communities, which can create situations where family members or those with other close personal relationships (associates) are working together. These situations are allowed but special care as described below must be taken to avoid conflict of interest.

Hiring managers must advise HR if a family member or associate is a candidate in a staffing process. Similarly, screening or selection board members must declare any relationships with prospective candidates to the hiring manager and CanNor HR. HR will provide guidance on steps to be taken to avoid preferential treatment.

Those with supervisory responsibilities must ensure that they are not involved in:

  • Direct and regular supervision of a family member or associate;
  • An audit or review of a relative's or associate's work;
  • Preparing a response to a grievance submitted by a relative or associate;
  • Selecting a relative or associate for education, training or development opportunities, or;
  • Making workforce adjustment decisions involving a relative or associate.

Measures to avoid these situations include, but are not limited to:

  • Changing reporting relationships;
  • Recusing yourself from decision making; and
  • Adjusting the membership of a selection board.

Chapter 4: Post-employment conflict of interest

4.1 Measures applicable to all employees

You have an on-going responsibility to minimize the possibility of conflict of interest between your most recent responsibilities within the federal public service and subsequent outside employment. Post-employment measures apply specifically to employment or association with external entities i.e., they do not apply to re-employment within the federal public sector.

You will be reminded of this responsibility before you resign or retire from the public service.

If you intend to pursue outside employment that may pose a risk of conflict of interest, you are required to file a disclosure before leaving the public service. If a post-employment conflict of interest is deemed to exist, you may be asked to modify or limit your plans. This will be done in writing and you will be asked to acknowledge that you have understood the decision and agree to apply the measures.

4.2. Measures applicable to employees in designated positions

Some positions are automatically subject to specific post-employment limitations that must be respected for one year after leaving the public service (limitation period). These positions are designated by the President.

Designation is based on factors such as the classification of the position (group and level), legislated and delegated authority, scope of influence and visibility within the community. HR is responsible for informing incumbents of designated positions of their status.

Note: Post-employment conflict of interest applies to your most recent responsibilities as a public servant. If you were acting in a designated position immediately before your resignation or retirement, the measures in this section will apply, even if your substantive position is not designated.

At CanNor, positions classified at the following levels are designated.

EX Minus 1 EX Equivalent EX
AS-07, CO-03, CT-FIN-04, EC-07, IS-06, IT-04, PE-06, PM-06 AS-08Table note *, CO-04, EC-08, IT-05Table note * EX-01, EX-02, EX-03, EX-04, EX-05Table note *
Table note *

These positions do not currently exist at CanNor, but will be designated if created.

Return to table note * referrer

If you are in a designated position, you may not do the following without the President's authorization during the one-year limitation period:

  1. Accept appointment to a board of directors of, or employment with, private entities with which you had significant official dealings during the one-year period immediately prior to leaving the Agency. The official dealings in question include those made through subordinates.
  2. Lobby on behalf of persons or entities outside of the public service with which you had significant official dealings during the one year period immediately prior to the termination of your service.Footnote roman numeral 6 The official dealings in question include those made through subordinates.
  3. Give advice to your clients or employer using information that you obtained through your work with CanNor and that is not publicly available.

Waiver or reduction of limitation period

You may apply to the President for a written waiver or reduction of the limitation period. Your request must include specific information as detailed in Subsection A.2.2.4.3 of the Directive on Conflict of Interest.

Conclusion

CanNor's Code of Conduct provides a framework of values and behaviours that guide us in all of our activities as we work to ensure that the North remains vibrant and strong. It is your responsibility to become familiar with the contents of the Code, to abide by its requirements and to seek guidance if you are unclear about the appropriate action to take. The Code is part of your conditions of employment.

Effective date

This Code of Conduct takes effect on April 1, 2025.

Evaluation

This Code will be evaluated 5 years after the effective date.

Appendix A: Duties and obligations

Persons employed

Persons employed at CanNor are expected to abide by this Code and demonstrate the values of the public sector in their actions and behaviours. Failure to do so may result in disciplinary action up to and including termination.

Persons employed are responsible to ask questions and seek guidance when expectations seem unclear. They also have an important role to play in creating and maintaining a work environment that reflects values and ethics.

If a person employed in CanNor has information that could indicate a serious breach of this Code, they can bring this matter, in confidence and without fear of reprisal, to the attention of their immediate supervisor, a more senior manager, the Senior Officer for Disclosure, or the Public Sector Integrity Commissioner.

President

The President of CanNor is responsible for establishing a Code of Conduct for CanNor and has overall responsibility for promoting a culture of values and ethics within the Agency.

The President is also responsible for designating Senior Officer for Conflict of Interest and Disclosure.

Finally, it is the responsibility of the President to ensure that the CanNor Code of Conduct and internal disclosure procedures are implemented effectively and are regularly monitored and evaluated. The President is also responsible for ensuring that CanNor programs and services are provided in a non-partisan manner.

Senior management

CanNor's Senior Management team supports the President in carrying out responsibilities related to values and ethics within this Code. They are responsible, collectively and within their respective teams, for promoting compliance with this Code and for fostering a values-based culture and high ethical standards of conduct that enable employees to work to their full potential in a professional and respectful work environment.

Managers

Managers are expected to uphold this Code, model appropriate behaviors, encourage dialogue on values and ethical issues, and foster an environment of openness where they encourage discussion and the exchange of ideas and promote the search for solutions.

Champion for values and ethics

The Champion for Values and Ethics supports the President in ensuring that CanNor exemplifies public service values at all levels of its organization. The Champion promotes awareness and understanding of the Public Sector Code and CanNor's Code of Conduct among employees, and ensures management practices are in place to support values-based leadership.

Senior officer for conflict of interest

The Senior Officer for Conflict of Interest (COI) puts the infrastructure and controls in place to administer the Directive on Conflict of Interest and to report to the Treasury Board Secretariat (TBS) as required. They ensure that COI risks are identified and resolved; that employees are informed and aware of the Directive, the CanNor designated positions, and post-employment responsibilities; and that employees are informed about COI decisions taken. A complete description of the responsibilities of the Senior Officer for Conflict of Interest can be found in the Directive.

Senior officer for disclosure

The Senior Officer for Disclosure helps promote a positive environment that allows persons employed at CanNor to securely and confidentially bring forward information concerning wrongdoing, and ensures that everyone is treated fairly and is protected from reprisal when they do so. The Senior Officer is responsible for supporting the President in meeting the requirements of the Public Servants Disclosure Protection Act (PSDPA). See Responsibilities of Supervisors and Senior Officers for more information on the Senior Officer's key responsibilities

Treasury Board Secretariat: Office of the Chief Human Resources Officer

The Office of the Chief Human Resources Officer (OCHRO) is the centre of expertise and leadership on values-based management and is also the policy centre for the Public Servants Disclosure Protection Act.

The OCHRO may issue directives, standards and guidelines related to departmental Codes of Conduct and will monitor the implementation of this Code at CanNor with a view to assessing whether the stated objectives have been achieved.

Public Service Commission

The Public Service Commission is responsible for conducting staffing investigations to safeguard the integrity of the public service staffing system and for administering certain provisions related to political activities to maintain the non-partisanship of the public service in accordance with the Public Service Employment Act.

Appendix B: Definitions

Condition of employment

A requirement that individuals must meet before being appointed to a particular position, and that must be maintained throughout their period of employment. For example, a security clearance and medical suitability are conditions of employment.

Conflict of interest

A situation, whether real, apparent or potential, in which the person employed has private interests that could influence the performance of their official duties and responsibilities or in which the person employed uses their office for personal gain.

  • Real: A conflict of interest situation that exists at the present time.
  • Apparent: A situation that could be perceived as a conflict of interest by a reasonable observer, whether or not it is the case.
  • Potential: A conflict of interest situation that could reasonably be foreseen to happen in the future.
Conflict of duties

A conflict, whether real, apparent or potential, that arises, not because of a public servant's private interests, but as a result of one or more concurrent or competing official responsibilities. For example, these could include the responsibilities of their primary public service employment and the responsibilities of an outside role that forms part of their official duties, such as an appointment to a board of directors or other outside function.

Family

Father, mother (alternatively, step-father, step-mother or foster parent), brother, sister, spouse (or common-law partner residing with an employee), child (including child of a common-law partner), employee's step-child or ward, grandchild, father-in-law, mother-in-law, employee's grandparent or any other relative permanently residing with the employee.

Persons employed

Comprises indeterminate and term employees of CanNor, including those on leave without pay, a person in casual status, a student hired under a Public Service Commission student program, a seasonal or part-time worker, or a person on secondment or Interchange Canada assignment with CanNor.

Appendix C: Reportable and exempt assets and liabilities

Reportable assets and liabilities (you must report these):

  1. Publicly-traded securities of corporations and foreign governments and self- administered Registered Retirement Savings Plans (RRSPs) and Registered Education Savings Plan (RESPs) that are composed of these securities, where these securities are held directly and not through units in mutual funds.
  2. Interests in partnerships, proprietorships, joint ventures, private companies and family businesses, in particular those that own or control shares of public companies or that do business with the government.
  3. Commercially operated farm businesses.
  4. Real property that is not for the private use of the public servant or their family members;
  5. Commodities, futures and foreign currencies held or traded for speculative purposes;
  6. Assets described in this section placed in trust or resulting from an estate of which the public servant is a beneficiary;
  7. Secured or unsecured loans granted to persons other than to members of the public servant's immediate family;
  8. Direct and contingent liabilities in respect of any of the assets described in this section; and
  9. Any other assets or liabilities that could give rise to a real, apparent or potential conflict of interest due to the particular nature of the public servant's official duties.

Exempt assets and liabilities (these do not need to be reported):

Assets and interests that are for the personal use of the employee or family, as well as property that is not of a commercial nature, are exempt assets that do not have to be reported. These assets include:

  1. Residences, recreational properties and farms used or intended for use by the public servant and their family;
  2. Household goods and personal effects;
  3. Works of art, antiques and collectibles;
  4. Automobiles and other personal means of transportation;
  5. Cash and deposits other than foreign currencies held for speculative purposes;
  6. Securities of fixed value issued or guaranteed by any level of government in Canada or agencies of those governments;
  7. Investments in limited partnerships that are not traded publicly and whose assets are exempt assets;
  8. Public sector debt financing not guaranteed by a level of government, such as university and hospital debt financing;
  9. Assets held in Registered Retirement Savings Plans (RRSPs) and Registered Education Savings Plans (RESPs), Tax Fee Savings Accounts (TFSAs) or other similar tax related savings vehicles that are not self-administered or self-directed;
  10. Investments in a diversified investment fund (i.e. a fund that does not concentrate its investments in specific businesses or industries, including but not limited to, diversified Exchange-Traded Funds "ETFs"), money market mutual funds and diversified mutual funds;
  11. Guaranteed investment certificates, certificates of deposit, and similar financial instruments;
  12. Annuities and life insurance policies;
  13. Pension rights;
  14. Money owed by a previous employer, client or partnership;
  15. Personal loans receivable from members of the public servant's immediate family and small personal loans receivable from other persons where the public servants has loaned the monies receivable.
  16. Any liability, such as a car loan, home renovation loan, or credit card account, from a financial institution or business entity granted on terms available to the general public.

Appendix D: Conflict of Interest disclosure process and processing standards

Disclosure process

  1. The employee completes the Conflict of Interest Disclosure ReportFootnote roman numeral 7 and the appropriate Assessment ToolFootnote roman numeral 8 and submits the two documents to the CanNor HR Confidential mailbox for disclosure. Note: An assessment tool is not required if a "NIL" disclosure report is being filed.
  2. CanNor HR acknowledges receipt.
  3. CanNor HR reviews the documents and seeks clarification or additional details from the employee if necessary.
  4. CanNor HR forwards the two documents to the executive closest to the employee in the hierarchy to complete the evaluation and recommendation portion of the assessment tool.
  5. CanNor HR reviews input from the executive and seeks clarification as necessary.
  6. The confidential report and assessment tool, together with a recommendation from CanNor HR, are sent to the Senior Officer for Conflict of Interest for decision.
  7. The Senior Officer advises the employee and appropriate executive of the decision.

During the process, there will likely be discussions between and among the parties involved to ensure full understanding of the disclosure and its possible impacts, as well as next steps. There may also be consultation with outside experts, or conversations with other executives within CanNor who might have relevant information or be impacted by the situation.

Processing standards

If you file a conflict of interest disclosure report, HR will normally acknowledge receipt of your documents within 3 working days. Documents must include the Conflict of Interest Disclosure Report and the relevant Assessment Tool.

Conflict of interest disclosures will be processed as expeditiously as possible. However, conflict of interest situations are often not black and white. Complex requests such as those that require advice from external experts may take as much as 90 days to complete. Processing time is counted from the date on which the properly completed forms are received in HR.

HR will keep you informed of the status of your disclosure. As a minimum, updates will be provided on a monthly basis.

Appendix E: References and enquiries

References

Legislation:

Policies:

Other:

Enquiries

  • Senior Officer for Conflict of Interest:
    Sean O'Donnell, Director General of Corporate Services & Chief Financial Officer
  • Senior Officer for Disclosure:
    Julie-Anne Miller, Corporate Secretary
  • Champion for Values & Ethics:
    Michael Walsh, Director General, Policy and Planning
  • Human Resources:
    Angela Pepper, Head, Human Resources
  • Office of the Public Sector Integrity Commissioner (PSIC)
    Telephone: 613-941-6400 or 1-866-941-6400

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