Waiver Granted Pursuant to Section 39

Issued under the Conflict of Interest Act
Statutory requirement(s):
39. (1)On application by a reporting public office holder or a former reporting public office holder, the Commissioner may waive or reduce any applicable period set out in section 36.
(5) If the Commisioner has granted a waiver or reduction in accordance with this section, the Commissioner shall publish the decision and the reasons in the public registry maintained under section 51.
51. (1) The Commisioner shall maintain a registry consisting of the following documents for examination by the public:
(d)
decisions on waiver or reduction applications under section 39 and the accompanying reasons.
Shiraz Keushgerian · Senior Advisor - Parliamentary Affairs and Issues Management
Other documents
Waivers (Section 39)
Disclosure date
December 13, 2024
Regime
Conflict of Interest Act

Description
Shiraz Keushgerian applied for a waiver of the limitation period that applies to former reporting public office holders for one year following their last day in office. The waiver of the limitation period allows him to accept an offer of employment with the Senate of Canada.

In reviewing his request, I considered all relevant factors listed under subsection 39(3) of the Act, which includes the following:

- The circumstances under which the reporting public office holder left his office:

Mr. Keushgerian is leaving his current employment to accept a position outside of politics. This will allow him to secure his career, find professional stability and maintain a better work-life balance.

- The general employment prospects of the reporting public office holder:

Mr. Keushgerian's employment prospects are primarily linked to the knowledge and skills he has acquired during his time as a ministerial staff. He has developed a broad knowledge of the functioning of Parliament, the legislative process and parliamentary procedure. He has also developed skills in providing strategic advice to managers.

- The authority and influence possessed by the reporting public office holder while in public office:

Mr. Keushgerian has no decision-making power. His level of authority and degree of influence within the office were limited.

In light of the above, I have determined that the public interest in granting the waiver in relation to the acceptance of an offer of employment with the Senate outweighs the public interest in maintaining the prohibition. I have therefore agreed to waive the limitation period for this contract.

All other post-employment obligations under the Act continue to apply, including the prohibition on contracting or accepting employment or an appointment to a board position with any other entity set out in subsection 35(1) as well as the prohibition on making any other representations within the meaning of subsection 35(2), for the remainder of Shiraz Keushgerian’s limitation period.