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First quarter (April to June) – Overview of statistical data and conflict of interest compliance for MPs and public office holders. First quarter of fiscal year 2026-2027 – April to June 2026 Individuals subject to conflict of interest regimes 342Members of the House of Commons1,366Reporting public office holders1,586Public office holders without reporting obligations (78 ministers and parliamentary secretaries, 741 ministerial staff,547 people appointed to other positions) (part-time members of federal boards,commissions and tribunals,and some part-time ministerial staff) Members of the House of Commons are elected. Public office holders are appointed. Conflict of interests prevention The Office helps Members of the House of Commons and Public office holders prevent conflicts of interests by: Members of the House of CommonsPublic office holdersContacting them as soon as they take office3 times 245 times Ensuring they complete the initial compliance process64 process203 processesGiving them advice139 times569 timesFollowing up with them every year0 reminders228 remindersPosting information in the public registry123 times239 timesTelling them about the post-employment rulesN/A62 times 51% of new reporting public office holders met all deadlines. The Office contacted new Members and public office holders within 3 business days in 75% of cases. Confidential advice When a Member or a public office holder has questions, they ask advisors at the Office for confidential advice. Members received advice 139 timesPublic office holders received advice 569 timesGeneral obligations: 35%General obligations: 36%Material changes: 24%Material changes: 19%Gifts and other benefits: 31%Post-employment obligations: 16%Letters of support and fundraising: 10%Outside activities: 11% Gifts or other advantages: 18% The number of requests for advice was higher than the last quarter. The Office responded to standard requests within 3 business days in 86% of cases. Public registry The Office added information to the public registry: Members of the House of CommonsPostingsPublic office holdersPostingsDisclosure summaries 75Agreed compliance measures5Gifts and other benefits 14Assets37Material changes 25Gifts or other advantages62Sponsored travel9Liabilities9Private interest0Outside activities38Total123Recusals9 Summary statements76 Travel3 Other0 Total239 The volume of postings was higher compared to the last quarter. The public registry is updated daily and can be accessed online.You can search it by date, type of declaration, regime, or an individual's name.The information in the registry is the only information the Office can make public. 5,000 public registry visitors 49,000 public registry views After a Member leaves office, their information is removed from the registry. Post-employment rules (Conflict of Interest Act only) All public office holders are subject to some rules even after they leave their position. 133 public office holders left office this quarter Former reporting public office holders face extra rules for one or two years after they leave office (cooling-off period) 826 former public office holders were in their cooling-off period They can ask for an exemption, waiver, or reduction of their cooling-off period 2 exemptions, waivers, or reductions granted Sanctions (Conflict of Interest Act only) 1 notice of violation sent Reporting public office holders who miss a reporting deadline may have to pay an administrative monetary penalty (fine). Before issuing a penalty, the Office sends them a notice of violation. Administrative monetary penalties Two $200 penalties for failing to provide,​ within 60 days of appointment, as part of the Confidential Report, all information that the Commissioner considers necessary to ensure compliance with the Act. ​​​​​All penalties are posted in the public registry​. Investigations (Act & Code) Case files opened and closed (a case file is a concern that is reviewed by the Office) 16 case files1 report published13 case files closed Subject of new case filesSource of new case files2 ministers or parliamentary secretaries9 members of the general public7 Members of the House of Commons5 Members of the House of Commons7 public office holders1 media 0 within the Commissioner's Office 1 Office of the Public Sector Integrity Commissioner The Office's target is to finish investigations in 12 months. Education and outreach Requests from the publicRequests from the mediaSocial media132 requests*53 media requests12 X posts 109 outside mandate0 interviews granted4,469 X followers23 within mandate2,150 media mentions 14,100 X mentions *See case files for investigation requests. 12 LinkedIn posts 1,313 LinkedIn followers WebsiteParliamentTraining and Education102,500 website visitors2 appearances9 presentations154,100 website views21% percentage of Question Periods where the Office was mentioned136 participants Responded to standard media requests within 4 hours in 96% of cases. Responded to standard public requests within 10 days in 84% of cases. To obtain the data used to produce this report, please contact us.

The Office of the Conflict of Interest and Ethics Commissioner is committed to transparency in its operations. It proactively discloses the Commissioner’s and employees' travel and hospitality expenses, the Office’s contracts over $10,000, and its annual financial statements. By September 30 each year, it posts financial statements for the previous fiscal year on this website. There is also information about the Office’s resources in its Financial statements. Proactive disclosureContractsHospitalityTravel Q1 - April to JuneQ1 - April to JuneQ1 - April to JuneQ2 - July to SeptemberQ2 - July to SeptemberQ2 - July to SeptemberQ3 - October to DecemberQ3 - October to DecemberQ3 - October to DecemberQ4 - January to MarchQ4 - January to MarchQ4 - January to March

List of sponsored travel The Commissioner’s Office publishes an annual List of Sponsored Travel by Members. By March 31 each year, it sends the Speaker of the House of Commons the list for the previous calendar year. The Speaker tables it in the House. Sponsored travel is any travel worth more than $200 that is not fully paid by the government, a political party, a recognized parliamentary association, or the Members. Under the Conflict of Interest Code for Members of the House of Commons, Members can accept sponsored travel for themselves and their guests but must disclose it to the Commissioner’s Office. Sponsored trips appear in the public registry throughout the year. List of Sponsored Travel Members’ Compliance Status Report The Members’ compliance status report​ shows where each Member is in the initial compliance process under the Conflict of Interest Code for Members of the House of Commons. That process begins soon after they are elected or re-elected, either in a general election or in a by-election. Updates to individual Members’ information appear in the public registry throughout the year. The Commissioner's Office publishes an update almost every month. It doesn’t update the status report during general elections. That’s because when the Governor General dissolves (ends) Parliament on the advice of the Prime Minister, Members of the House of Commons are no longer Members. Members’ Compliance Status Report

The Commissioner’s Office publishes a Members' Compliance Status Report that identifies where each Member is in the initial compliance process under the Conflict of Interest Code for Members of the House of Commons on a specific day. It is updated every month. Please click on the following link to view the most recent report.

Investigation reports The Commissioner reports publicly on investigations of people who may have broken the rules of the Conflict of Interest Act, or the Conflict of Interest Code for Members of the House of Commons. Investigations are called “examinations” under the Act, and “inquiries” under the Code. The titles of most investigation reports contain the names of the Members or public office holders who were investigated. Ministers and parliamentary secretaries, who must follow the Act and the Code, may be investigated under both sets of rules. Investigation reports Investigation report summaries This table summarizes all the public reports the Commissioner’s Office has released on investigations under the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. It lets you sort them by when they were released, the person the Commissioner investigated, what claims led to the investigation, and what rules the Commissioner considered. You can also see at a glance if those rules were broken. Investigation report summaries

This searchable database is where you can find everything the Commissioner’s Office can make public about elected and appointed officials. It contains all the information that Members and reporting public office holders must publicly declare under the Conflict of Interest Act, and the Conflict of Interest Code for Members of the House of Commons. Publicly declaring information means sharing information that the Commissioner’s Office makes available for anyone to see. Start your search by using the links on the left. To return to the website of the Commissioner’s Office, you can click on the "Home" button in the top menu. NOTE: Declarations submitted before April 25, 2015, are in the preferred language of the reporting public office holder or Member of the House of Commons. Search the public registry Conflict of Interest Act The public registry contains the public declarations of ministers, parliamentary secretaries, ministerial staff and other individuals that the Act calls “reporting public office holders.” Their information stays in the registry for their whole time in public office. It remains in the registry, along with the date they started post-employment, until their cooling-off period (two years for former ministers and one year for all other former reporting public office holders) is over. Then it is no longer available from the Commissioner’s Office. NOTE: Declarations made before 2007 under the previous conflict of interest regime are no longer available online. Conflict of Interest Code for Members of the House of Commons The public registry contains information that Members must publicly declare. It contains information for current Members only. Once someone stops being a Member, their information is removed from the registry and is no longer available from the Commissioner’s Office. When a Parliament is dissolved, triggering a general election, the Code no longer applies, so Members’ information is removed from the registry. After the election, information for new and re-elected Members is posted in the registry when they complete the initial compliance process under the Code. The Members' Compliance Status Report shows where each Member is in the initial compliance process. It is updated every month. Expand all Collapse all All results published under the Act The public registry of compliance documents required under the Conflict of Interest Act contains the Summary Statements of ministers, parliamentary secretaries and other reporting public office holders, as well as their public declarations relating to gifts or other advantages, travel, certain assets and liabilities, outside activities, and other declarations as necessary. Within 60 days of their appointment, reporting public office holders must file with the Conflict of Interest and Ethics Commissioner a Confidential Report describing their assets, liabilities, income, and activities. A Summary Statement is prepared and placed in the public registry. Reporting public office holders are not required to sign or make public a new Summary Statement every year. They are only required to review annually the information they disclosed and, if there are any changes, to inform the Commissioner. Unless a change also modifies the information that has been made public, the Summary Statement remains the same and continues to be valid, regardless of the date on which it was signed. Reporting public office holders' information can be accessed in the registry throughout their time in public office. It remains in the registry until they have completed their one- or two-year cooling-off period under the Act's post-employment provisions, then is no longer available from the Office. The date a reporting public office holder started post-employment is noted in the registry. All results published under the Code The public registry contains information that Members are required to publicly disclose under the Conflict of Interest Code for Members of the House of Commons, including their Disclosure Summaries and public statements relating to gifts or other benefits, sponsored travel and material changes. Within 60 days after notice of their election is published in the Canada Gazette, Members must file with the Commissioner a confidential Disclosure Statement describing their private interests and those of family members. A Disclosure Summary is prepared and placed in the public registry. Each Disclosure Statement is reviewed at least once a year and updated if necessary. If there are no changes to the information that Members are required to make public, no new Disclosure Summary is required; the most recent one remains valid. Members are required to sign a new Disclosure Summary after each election. The registry contains information for current Members only. Once an individual ceases to be a Member, their information is removed from the registry and is no longer available from the Office. When a Parliament is dissolved, triggering a general election, Members of the House of Commons are no longer considered Members, so their information is removed from the registry. After the election, information for new and re-elected Members is posted in the registry when they complete the initial compliance process under the Code. The Members' Compliance Status Report provides information about where each Member is in the initial compliance process. It is updated as required, and more frequently after general elections.

Annual reports The Commissioner’s Office publishes two annual reports on its activities, as required by section 90 of the Parliament of Canada Act, by June 30 each year. One is on the administration of the Conflict of Interest Act. The other is on the administration of the Conflict of Interest Code for Members of the House of Commons. The annual report on the Act is tabled in the Senate and the House of Commons. The one on the Code is tabled in the House. Annual reports Financial reports The Commissioner’s Office is committed to transparency in its operations. It proactively discloses travel and hospitality expenses, and contracts over $10,000 for each quarter (three-month period) of the federal government’s fiscal year. By September 30 each year, it publishes financial statements for the previous fiscal year. It also includes a financial resources summary in its annual reports. The Commissioner’s Office does not produce reports on plans and priorities, or departmental performance reports, because it is part of Parliament. Financial reports Accessibility reports The Commissioner’s Office reports each year on the work it is doing to implement the Accessible Canada Act and its regulations. The aim of the Act is to make Canada barrier-free by January 1, 2040. Accessibility reports Quarterly statistical reports The Commissioner's Office publishes statistical reports to show how its activities line up with its mission, and to track its workload and spot trends. They contain information on how it advises individuals covered by the Conflict of Interest Act and/or the Conflict of Interest Code for Members of the House of Commons, educates and reaches out to people, and enforces both sets of rules. They also show how well it is meeting its service standards. Each report covers one quarter (three months) of the federal government’s fiscal year. A fiscal year is a 12-month period that the government uses for financial planning, budgeting, and reporting. There are four quarters in each fiscal year: April 1–June 30July 1–September 30October 1–December 31January 1–March 31 Each report comes out about a month after the quarter ends. The combined data for the whole fiscal year are included in the Commissioner's annual reports. Quarterly statistical reports Public office holder surveys The Commissioner’s Office conducts surveys of people subject to the Conflict of Interest Act. It uses the results to better understand their needs, and to learn what works well and what it can do better to help them follow the rules. It surveyed public office holders in 2022, for the first time since the Act took effect in 2007. Public office holder surveys

The Commissioner’s Office publishes an annual List of Sponsored Travel by Members. By March 31 each year, it sends the Speaker of the House of Commons the list for the previous calendar year. The Speaker tables it in the House. Sponsored travel is any travel worth more than $200 that is not fully paid by the government, a political party, a recognized parliamentary association, or the Members. Under the Conflict of Interest Code for Members of the House of Commons, Members can accept sponsored travel for themselves and their guests but must disclose it to the Commissioner’s Office. Sponsored trips appear in the public registry throughout the year. WIDGET 1 - Sponsored travel

This report summarizes the Office’s work in administering the Conflict of Interest Code for Members of the House of Commons. That work includes compliance activities, education and outreach initiatives, and investigations. Tabling letter Dear Mr. Speaker: I am pleased to submit to you the report on the performance of my duties and functions under the Conflict of Interest Code for Members of the House of Commons for the fiscal year ending March 31, 2026, for tabling in the House of Commons. The report is deemed permanently referred to the House of Commons Standing Committee on Procedure and House Affairs, under Standing Order 108(3)(a)(vii). This fulfills my obligations under paragraph 90(1)(a) of the Parliament of Canada Act. Sincerely, Hon. Konrad von Finckenstein, C.M., K.C. Conflict of Interest and Ethics Commissioner​ Commissioner's message I am pleased to submit to the House of Commons my annual report on the administration of the Conflict of Interest Code for Members of the House of Commons, as required by paragraph 90(1)(a) of the Parliament of Canada Act. In 2025-2026, the Commissioner's Office continued to follow a mandate-focused approach that supports three key objectives, within the framework of its five-year strategic plan. The first is to help elected and appointed officials manage their conflicts of interest so competent and qualified people can move in and out of public service without difficulty. We offer training and educational resources to help them understand and follow the rules, and give them confidential advice. People with experience outside of the public sector may face potential conflicts of interest because of their business relationships. In addition, anyone may have personal relationships, social connections or investments that could create conflicts of interest. We identify such conflicts by reviewing Members' personal and financial information. A second objective is to review and report on allegations of conflict of interest. When we receive information that someone may have contravened the Code, we may open a case file to review it. If there are reasonable grounds to believe there was a contravention, we will investigate. While not all case files result in investigations, and not all investigations result in reports, enforcing the Code is a core part of our mandate. Everything we do ultimately supports a third key objective: helping Canadians trust that the actions of elected and appointed federal officials are free from conflicts of interest. The Code includes transparency requirements, and the Commissioner's Office reports to Parliament and releases public reports. We also share as much information as we can through our website and when responding to requests for information. The April 2025 general election resulted in high turnover among elected and appointed officials, and more compliance work for the Commissioner's Office. We supported all 343 Members of the House of Commons in meeting their initial compliance requirements under the Code. Most Members completed the initial compliance process by the end of 2025-2026, and the rest were in the final stages of completion. The volume and complexity of the work meant it was not possible to get them all through the initial compliance process as soon as we would have liked. In the year ahead, we will look at whether there are any changes we can make to our processes and capacity to better support periods of high turnover around general elections. We submitted two new guidelines and five revised forms under the Code to the House of Commons Standing Committee on Procedure and House Affairs for approval. The Committee approved them and recommended that the House of Commons do the same. As of March 31, the House had not concurred in the Committee's report. Going forward, we will continue to follow our mandate-focused approach. We remain flexible and ready to respond to new challenges.​ Vision, mission, and mandate Vision To safeguard public confidence in the integrity of Parliament and government institutions. Mission To help elected and appointed public officials avoid conflicts of interest. Mandate Administer the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act to manage conflicts of interest and safeguard public trust. Helping elected officials manage conflicts of interest A key objective of the Commissioner's Office is to help people elected to the House of Commons manage potential conflicts between their public duties and private interests, so the most competent and qualified people can move in and out of public service without conflicts of interest. Avoiding conflicts of interest is one of four focus areas in its 2025-2030 strategic plan. Each focus area is a framework for purposeful projects and initiatives, and the plan itself is reviewed every year. Activities in this focus area include simplifying compliance processes, giving Members of the House of Commons clear and consistent advice, and offering education and training that meets their specific needs. When an elected official has competing interests that could interfere with their ability to be fair and objective when doing their job, their judgment could be affected by the possibility of benefitting themselves or someone they know. The Conflict of Interest Code for Members of the House of Commons aims to prevent that from happening. Under the Code, Members are in a conflict of interest when they act in any way to further their private (mostly financial) interests or those of a family member, or to improperly further another person's or entity's private interests. The Commissioner's Office helps Members ensure their actions, while performing their parliamentary duties and functions, are free from conflicts of interest. This makes it easier for experienced and competent people to move in and out of public office, in keeping with the purposes of the Code: To maintain and enhance public confidence and trust in the integrity of Members, as well as the respect and confidence that society places in the House of Commons as an institution. To demonstrate to the public that Members are held to standards that place the public interest ahead of their private interests, and to provide a transparent system by which the public may judge this to be the case. To provide for greater certainty and guidance for Members on how to reconcile their private interests with their public duties and functions. To foster consensus among Members by establishing common standards and by providing the means by which questions relating to proper conduct may be answered by an independent, non-partisan advisor. Who is subject to the Code The Conflict of Interest Code for Members of the House of Commons applies to all 343 elected Members. The Code applies in the same way to all elected Members. However, some additional obligations and restrictions apply to those who are ministers, secretaries of state or parliamentary secretaries, because they are also subject to the Conflict of Interest Act as reporting public office holders. Figure 1: Snapshot of Members on March 31, 2026 38 min​isters​​10 secretaries of state​39 parliamentary secretaries​253 Members who are not ministers or parliamentary secretaries​340 Members The number of Members may go up and down during the year if some seats become vacant and by-elections are held. There were greater fluctuations in 2025-2026 because of the April 2025 general election. When a Parliament is dissolved, triggering a general election, Members of the House of Commons are no longer considered Members and the Code does not apply. There was also one by-election. The Commissioner's Office tracks these changes in its quarterly statistical reports. Anyone elected to public office may face potential conflicts of interest because of their family and social connections, business and professional relationships, and financial investments. Their private interests and those of their family could be affected by decisions they might be called on to make or participate in. The more experience people have outside of government, the more likely they will have such conflicts. The Commissioner's Office helps Members identify and manage potential conflicts of interest by making sure they understand the Code's rules, guiding them on how to submit required information, and advising them on how to follow the rules. Personal confidential advice The Commissioner's Office assigns each Member of the House of Commons an advisor to help them understand and follow the rules and guide them on meeting the Code's reporting requirements. They can at any time ask their advisor for confidential advice tailored to their personal situation. Figure 2: Advice by topic in 2025-2026​ General obligations​​​205Gifts and other benefits104Material changes80Letters of support and fundraising69Total458 The Commissioner's Office tracks the topics Members ask about every quarter (three-month period) and updates its training and communications to focus on those topics. Requests for advice often reflect what is being talked about in the news. For example, after an election, the Commissioner's Office receives more questions about general obligations and disclosures. The advice the Commissioner's Office gives individual Members is confidential. It will not share that advice with anyone else or make it public unless the Member formally asks it to. Members are not bound by the same confidentiality requirements. They are free to share information about any advice they receive from the Commissioner's Office. Education and training The Commissioner's Office offers Members flexible and accessible learning opportunities to help them understand the rules and other requirements of the Conflict of Interest Code for Members of the House of Commons. It communicates with them directly throughout their time in public office. When they are first elected, it sends them information that explains the rules they must follow. During their term, the Office shares the Commissioner's reports and any other information that may be relevant to them. These and other communications are part of an outreach strategy that includes education and training opportunities designed to be flexible and accessible. The Commissioner's Office continually updates the strategy to reflect current information needs and emerging trends. It offers Members and the staff who support them live online and in-person training, and interactive learning tools. In 2025-2026, the Commissioner's Office held four educational sessions on the Code. The Commissioner’s Office offered presentation on the Code to party caucuses after the April 2025 general election. One presentation was delivered. The Code requires the Commissioner's Office to provide mandatory training on the Code for Members, who must complete it within 120 days after their election is confirmed. It has developed an online, self-directed course that Members can access through Source (the parliamentary intranet). The course, which includes real-life scenarios and interactive elements, helps Members understand the rules, how to manage potential conflicts of interest, and when to seek guidance. Of the Members whose election was confirmed in 2025‑2026, 328 (over 96%) completed mandatory online training on the Code by March 31, 2026. Guidance on reporting requirements Under the Conflict of Interest Code for Members of the House of Commons, Members must give the Commissioner's Office detailed personal and financial information for themselves and their family members. Most of it is kept private, but some is posted in the public registry as required by the Code. The Code's initial and ongoing reporting requirements ensure the Commissioner's Office has the information it needs to help Members avoid conflicts of interest. They also support transparency. All Members must complete an initial compliance process. It features one‑on‑one meetings with their assigned advisor at the Commissioner's Office that are an opportunity to: walk through the Code's rules in detailunderstand how its requirements apply to their specific dutiesexplore the nuances of their file or circumstancesclarify expectations and reporting timelinesask questions in a confidential environment. The initial compliance process includes two separate 60-day periods, separated by an unspecified amount of time. The first 60-day period starts when notice of a Member's election or re-election is published in the Canada Gazette. It ends when they give their advisor in the Commissioner's Office a confidential Disclosure Statement (containing detailed information on their assets, liabilities, outside activities and other interests and those of their family members) and supporting documents, like financial statements. In the time between the two 60-day periods, their advisor reviews the Disclosure Statement and advises them on how to organize their affairs to avoid conflicts of interest. They then prepare a summary (called a disclosure summary) of the information in the Disclosure Statement for the Member to review and approve. Factors that affect how much time this takes include the file's complexity, the information's completeness, the Member's availability, and the advisor's workload. The second 60-day period starts when the Member receives their disclosure summary. It ends when the Commissioner's Office receives the approved summary. When the Commissioner's Office posts the summary in the public registry, the initial compliance process is over. By March 31, 2026, the initial compliance process was completed for 270 Members. While in office, Members must meet ongoing reporting requirements. They must tell the Commissioner's Office about the following things, within certain deadlines, and some of this information is made public: Material changes (any changes to the information in their Disclosure Statement).Gifts and other benefits worth $200 or more that they or their family members accept, and multiple gifts received from one source in a 12-month period with a total value of $200 or more.Sponsored travel (any travel worth more than $200 that is not fully paid by the government, a political party, a recognized parliamentary association, or by the Members themselves).Abstentions. If present when a matter they have a private interest in is being debated or voted on in the House of Commons or by a committee they are part of, Members must disclose the general nature of the interest to the Clerk of the House of Commons. The Clerk will send the disclosure to the Commissioner, who will post it in the public registry. If they have a private interest that could be affected by their parliamentary work in other situations, they must inform the party concerned about the general nature of the interest and send a written notice about it to the Commissioner, who will post it in the registry. Figure 3: Public declarations by Members in 2025-2026​ Disclosure summaries285Gifts and other benefits20Material changes15Sponsored travel25Private interest0Total345 In 2025-2026, the number of public declarations was down 24% from the year before, mostly because Members filed fewer notices of material change (a change to any of the information in the Disclosure Statement that they fill out during the Code's initial compliance process). All Members had to complete the initial compliance process after the April 2025 general election, so there was no information on file for them to change. Each year, Members must complete an annual review that involves going over their information with their advisor at the Commissioner's Office and updating it as needed. No annual reviews were done in 2025-2026. That is because all Members had to complete the initial compliance process after the April 2025 general election. Figure 4: Compliance processes completed in 2025-2026 Initial compliance processes completed270Annual reviews0 Reviewing and reporting on alleged conflicts of interest Enforcing the Conflict of Interest Code for Members of the House of Commons is a core part of the Commissioner's mandate. It is captured in one of the key objectives of the Commissioner's Office: to review and report on allegations of conflict of interest involving elected and appointed officials. It also relates to a focus area of its strategic plan: avoiding conflicts of interest. Enforcing the Code by investigating possible conflicts of interest provides transparency and accountability. Investigations The Commissioner can start an investigation (called an inquiry) under the Code in one of three ways: When asked to investigate by a Member of the House of Commons who has reasonable grounds to believe that another Member has contravened the Code. The Commissioner's Office received three inquiry requests from Members in 2025-2026.When directed to by the House of Commons (this has never happened).On his own initiative if he has reasonable grounds to believe, based on information from any source, that a Member may have contravened the Code. The Commissioner's Office received six inquiry requests from members of the public in 2025-2026. When the Commissioner finds in an inquiry that a Member has contravened the Code, he may recommend appropriate sanctions. However, it is the House of Commons that decides whether or not to impose any sanctions. Inquiry reports are made public on the website of the Commissioner's Office, and in the public registry. They are educational tools that can help Members understand how the rules apply and prevent future conflicts of interest. They also support transparency and accountability. The Commissioner did not issue any inquiry reports in 2025-2026. Case files The Commissioner's Office opens a case file if it becomes aware of a concern or an allegation that a Member may have contravened the Code. This does not mean it is investigating, but is simply reviewing the matter to determine if there are grounds to investigate. When the Commissioner's Office opens a case file, it gathers and reviews all relevant information from public sources. This is called an initial review. Not all case files result in inquiries. The Commissioner will investigate only if he finds that an inquiry is warranted. If he finds an inquiry is not warranted, the case file is closed. When a Member has provided reasonable grounds to believe another Member has not met their obligations under the Code and asks the Commissioner to investigate, the Commissioner's Office does not open a case file. Instead, it follows a process set out in the Code for dealing with valid inquiry requests: The Commissioner forwards the request without delay to the Member named in it and gives them 30 days to respond.After receiving the response, the Commissioner's Office conducts a preliminary review to determine if an inquiry is warranted.Within 15 working days of receiving the response, it notifies the Members involved whether or not the Commissioner will conduct an inquiry. In the meantime, the Member who requested an inquiry is not allowed to say anything about it publicly until the Commissioner has completed the preliminary review and notified the Members involved.​ Case files (a case file is a concern or allegation reviewed by the Commissioner's Office) Total case files: 9 Ongoing: 3 Closed without an examination: 6 Closed with publication of report: 0 Figure 5: Breakdown of case files in 2025-2026​​ ​​ Subject of each case file​​​​Current or former Member of the House of Commons9​​Source of these case files ​Member of the House of Commons3Media0​Member of the general public​6Within the Office​0​​​Nature of the concernFurthering a private interest (section 8 of the Code)3Required disclosure of information (sections 20 to 24)​2Sponsored travel (section 15)2Gifts and other benefits (section 14)​1 Fostering public confidence Helping Canadians trust that the actions of elected and appointed federal officials are free from conflicts of interest is a key objective of the Commissioner's Office. In fact, everything it does ultimately supports this objective, including projects and activities in three focus areas identified in its strategic plan: Avoiding conflicts of interest – Communicating clearly and accessibly about the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons to support transparency and accountability. User-friendly experience – Ensuring that public office holders have positive interactions with the Commissioner's Office so they feel comfortable asking for advice when faced with potential conflicts of interest. Tools, knowledge and skills – Making sure employees have what they need to fulfill the Commissioner's mandate effectively. As an independent, non-partisan entity, the Commissioner's Office is well placed to ensure impartial oversight, prevent political interference, and promote accountability. Supporting transparency The Commissioner's Office is as open as possible with Parliament and Canadians. That is because transparency is key to public trust. When information is shared, people can see that the rules are being followed. Transparency is built into the Conflict of Interest Act through its public declaration requirements. Some of the information that reporting public office holders must give the Commissioner's Office is posted in the public registry. Transparency is balanced by the Act's confidentiality provisions, which encourage public officials to communicate freely and openly with the Commissioner's Office. The Commissioner's Office respects this balance. When asked to share or comment on confidential matters, it directs those who ask to the public registry. Public registry A searchable database that can be accessed through the Office’s website, the public registry contains all the information about current Members that the Commissioner is allowed to share. Figure 6: Public registry postings and views Postings Views2025-20261,248190,000Five-year average1,260126,900 The public registry was accessed 520 times a day on average in 2025-2026. It tends to get more visitors when an issue about someone’s disclosures comes up in the media, or if the Commissioner’s Office has posted information in the registry about a high-profile official. When Parliament is dissolved (as it was in March 2025), triggering a general election, Members of the House of Commons stop being Members, so the Commissioner’s Office removes their information from the registry. After a general election, information for new and re-elected Members is posted in the registry once they have completed the Code’s initial compliance process. Reporting to Parliament The Commissioner has a duty to report to Parliament, testify before parliamentary committees, and answer questions from Parliament. As an independent Officer of the House of Commons, he reports to Parliament directly, not through a minister. By June 30 each year, the Commissioner sends a report on the administ​ration of the Conflict of Interest Act to the Speakers of the Senate and the House of Commons for tabling. The Commissioner's Office sends communiqués to parliamentarians about its reports and other activities. It sent seven of these in 2025-2026. The House of Commons Standing Committee on Access to Information, Privacy and Ethics has oversight responsibility for the Commissioner's Office. The Committee reviews its annual spending estimates, and matters related to the Commissioner's reports under the Act. Figure 7: Committee appearances in 2025-2026 September 15, 2025 House of Commons Standing Committee on Access to Information, Privacy and Ethics Briefing session with the Conflict of Interest and Ethics Commissioner Commissioner von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance Melanie Rushworth, Director, Communications, Outreach and Planning​ October 30, 2025 House of Commons Standing Committee on Procedure and House Affairs (in camera) Forms and guidelines under the Conflict of Interest Code for Members of the House of Commons Commissioner von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance Michael Aquilino, Legal Counsel December 8, 2025 House of Commons Standing Committee on Access to Information, Privacy and Ethics Review of the Conflict of Interest Act Commissioner von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance Michael Aquilino, Legal Counsel In October 2025, the Commissioner asked the Standing Committee on Procedure and House Affairs to approve two new guidelines and five revised forms under the Code. It was confirmed during this process that all changes to guidelines and forms, no matter how minor, must be submitted to the Committee for approval. The Committee recommended that the House of Commons approve the documents in a report to the House. As they are now public, the Commissioner's Office can identify them here: Writing letters of support (guideline)Gift rules for Members of the House of Commons (guideline)Request for an inquiry under the Code (form)Members' compliance status report (form)Public statement of gifts or other benefits (form)Public statement of sponsored travel (form)Disclosure statement for Members and their family members (form) Once approved by the House of Commons, the new guidelines will give Members consistent information on two important topics. The revised forms reflect plain language principles and feature brief explanatory text, to make them easier to use.​ Public communications The C​ommissioner’s Office shares as much information as it can with the public, and in different ways, under the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.​ It posts information on its website and on social media and responds to information requests from the media and members of the public. Figure 8: Website users and page views in 2025-2026 2025-2026Website users218,700Website page views366,500 In 2025-2026, the website attracted 70% more users and 30% more page views than the year before. The Commissioner's Office also continued to work with House of Commons IT Services on the development of a redesigned website. Figure 9: Social media presence in 2025-2026 X@EthicsCanada LinkedIn@ethics-ethique-canada Posts4244Followers4,4451,262 The Commissioner's Office uses social media to share information about its activities and updates from the public registry that may be of interest to journalists, academics, Canadian and international ethics practitioners, and others. Media inquiries in 2025-2026 Emails and phone calls from the media: 147 Over 80% were questions about a specific elected or appointed official, including questions about their public disclosures and compliance measures About 20% were general inquiries about the Office's role and mandate and activities It responds to journalists and members of the public who seek information by explaining how the Act and the Code work, and by directing them to the public registry when appropriate. Public inquiries related to the Office in 2025-2026 Emails, letters, and phone calls from members of the public: 1,668 10% were general inquiries about the role of the Office. 75% were complaints about an elected or appointed official. Some were shared with the Investigations division for follow-up. Complaints are often based on observations made on the public registry or items that are discussed in the news. For example, this includes a coordinated email campaign describing an allegation against a minister. The Office responded to all 800+ emails by explaining that the minister's alleged behaviour was not covered by the Commissioner's mandate. 15% were general complaints about the activities of individuals that may not have been subject to the Act or the Code, about Members' floor crossings and behaviour in the House of Commons, and their use of social media. The Commissioner's Office received three times more public inquiries than in the previous year. This increase is likely due to the email campaigns mentioned above. Most of these inquiries were not directly related to the Office's mandate and the senders are informed that their concerns will not be acted on. Nevertheless, responding to these inquiries allows the Office to further explain how the rules work and are applied. The Commissioner's Office is transparent about what it does. For example, it publishes quarterly statistical reports that contain data on its activities, and tracks how it meets its service standards: Contact new or re-elected Members within 3 business daysRespond to Members' requests for advice within 3 business daysAnswer media inquiries within 4 hoursAnswer inquiries from other members of the public within 10 business days​ It met all these service standards for 2025-2026 as a whole. Connecting with others The Commissioner's Office works with other organizations to stay updated on and share best practices. This supports its objective of fostering public confidence that elected and appointed officials' actions are free from conflicts of interests. Participation in these networks helps it strengthen its internal expertise. It continues to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN) of federal, provincial, and territorial conflict of interest commissioners. In September 2025, the Commissioner, the Director of Communications, Outreach and Planning and another Office representative attended CCOIN's annual meeting, hosted by Conflict of Interest Commissioner Victoria Gray in Victoria, British Columbia. Commissioner von Finckenstein and Senate Ethics Officer James O'Reilly will welcome CCOIN commissioners to Ottawa in September 2026. The Réseau francophone d'éthique et de déontologie parlementaires (RFEDP) promotes exchanges between parliaments and entities in the Organisation internationale de la Francophonie [link in French only] that are interested in ethics and codes of conduct. The Commissioner's Office is a founding and active member. RFEDP activities in 2025-2026: At the RFEDP's Annual General Assembly held in Paris in July 2025, the Commissioner's Office was appointed Vice‑President of the RFEDP Bureau. Its representative for the post is the Director of Communications, Outreach and Planning. Throughout the year, the Commissioner's Office contributed to the Bureau's regular meetings and supported the integration of new members. It strengthened its leadership role in the RFEDP by creating a workshop called “Developing ethical and deontological reflexes." This training supports member countries in addressing common parliamentary ethics challenges. It delivered the online workshop to Burundian parliamentarians in June 2025 and collaborated with several RFEDP partners—among them the School of Advanced Political and Legal Studies and Professor Charles Moumouni (Laval University)—to tailor the content to diverse national contexts. A second, more interactive version of the workshop was delivered to parliamentarians and academics in the Democratic Republic of Congo in February 2026. The Commissioner's Office actively participated in RFEDP-led sessions on the exchange of best practices. The Commissioner's Office is part of the Council on Governmental Ethics Law (COGEL), an international network of professionals working in government ethics, lobbying regulation, elections administration, campaign finance, and freedom of information. COGEL promotes integrity and transparency in government by supporting training, professional development, and the exchange of expertise among practitioners from different jurisdictions. Representatives of the Commissioner's Office attend COGEL's annual conference and participate in virtual activities throughout the year. These events are opportunities to exchange knowledge and collaborate with counterparts working in conflict of interest and related fields. In 2025-2026, the Commissioner's Office shared its expertise when representatives participated as speakers on two panels at the COGEL conference. Managing the Commissioner's Office The administration of the Conflict of Interest Act is supported by the employees, policies and processes of the Commissioner's Office. The need to continually maintain and strengthen this infrastructure is reflected in two focus areas of its strategic plan: Healthy and fulfilling workplace – Activities include keeping employees engaged and motivated, promoting inclusivity and equity, and respecting and supporting bilingualism. Tools, knowledge and skills – Activities include offering employees comprehensive training, implementing coherent information management practices, and facilitating the sharing of expertise. A team of 51 employees supports the Commissioner. They have expertise in areas like compliance, law, communications, corporate management, investigations, and parliamentary relations. The Commissioner provides overall direction and makes the decisions that need his input and approval. He works closely with other members of the Office's Senior Management Committee. Commissioner Konrad von Finckenstein (centre) with (from left to right): Martine Richard, Senior General Counsel, Investigations and Legal Services Sandy Tremblay, Director, Corporate Management Lyne Robinson-Dalpé, Director, Advisory and Compliance Melanie Rushworth, Director, Communications, Outreach and Planning Lyne Robinson-Dalpé retired in the last quarter of 2025-2026 after more than 20 years of dedicated service to the Commissioner’s Office in a 35-year career of public service. Lisa DeMoor has now joined the Office as Director, Advisory and Compliance. Under the Commissioner's leadership, employees handle the daily tasks of administering the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. They make sure the processes and structures are in place to support their administration. These include strong internal controls to manage public money responsibly, protect public assets, and use resources in an effective and efficient way. An independent auditor reviews the Office's financial statements every year. Financial information for 2025-2026 is outlined in the Appendix. Accessibility Office employees also work on other important files like compliance with the Accessible Canada Act. In December 2025, the Commissioner's Office released its second accessibility plan, for the 2025 to 2028 period. The updated plan builds on its 2024 progress report and incorporates best practices from its 2023-2025 accessibility plan. It outlines commitments to remove barriers across all priority areas under the Accessible Canada Act, and introduces new elements like culture, SMART objectives, and enhanced consultation processes. Supporting bilingualism In 2025-2026, the Commissioner's Office reviewed and updated its Policy on Official Languages. The language requirements assigned to positions reflect employees' duties and work units, and obligations under the Official Languages Act related to service to the public and language of work. All term and indeterminate positions designated as bilingual are staffed with individuals who have the required linguistic profile. The Commissioner's Office actively offers communications and services in both English and French. In particular, it: gives members of the public a clear choice to communicate in their preferred official language when initiating contact with them, and continues communications in the language chosen by the member of the public. The Commissioner's Office makes the English and French versions of all written communications to the public available at the same time, and ensures they are of equal quality, no matter what communication method it uses. Information management The Commissioner's Office follows information management practices that include destroying its files on former public office holders who have been in post-employment under the Conflict of Interest Act for more than 10 years. It identifies all internally held files of individuals who have passed this 10-year limit. Then it deletes their electronic information from the Office's records management system. If there are physical files, it shreds them. Training The Commissioner's Office makes sure employees get the right training so they have the knowledge and skills to do their jobs and help fulfill its mandate. In 2025-2026, it started refining its onboarding process, which is designed to welcome new employees and give them clear, practical guidance from the moment they join the Commissioner's Office. It brings together what they need to know about their role, the Commissioner's mandate, and how the Office works day-to-day, so they can contribute to a healthy, respectful and effective workplace. Step‑by‑step checklists, orientation activities and follow‑up milestones help ensure each employee has the tools, knowledge and support they need to succeed in their new position, and feels part of the Office's mission from the start. The Commissioner's Office offers employees ongoing training on systems and tools, and occasional training on policies and procedures. For example, in March 2026, harassment and violence prevention training was provided to all employees. Each year, the Commissioner's Office identifies job-specific training opportunities in employees' individual learning and development plans. It also promotes the sharing of expertise, including soft skills, within the Office and through employees' active participation in external knowledge groups. Crisis communications plan In September 2025, the Senior Management Committee adopted a crisis communications plan. It identifies several scenarios that would require a crisis communications approach. Staffing To make sure it has the right positions and the right people in them to support its mandate, the Commissioner's Office ran seven staffing processes in 2025-2026. In June, it submitted its first Pay Equity Annual Statement to the Office of the Pay Equity Commissioner. Appendix: Financial resources summary (thousands of dollars) Program Activity 2024-2025 2025-2026Alignment to Government of Canada OutcomesActual Spending ​Main Estimates ​Total Authorities ​Actual Spending Administration of the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act 7,594 8,152 8,152 7,984 Government Affairs Contributions to employee benefit plans 939 1,013 1,013 960 Total spending 8,533 9,165 9,165 8,944 Plus: cost of services received without charge 918 N/A N/A 998 Net cost of department 9,451 9,165 9,165 9,942 The Office of the Conflict of Interest and Ethics Commissioner’s budget process is set out in the Parliament of Canada Act. Before each fiscal year, the Office prepares an estimate of its budgetary requirements. The Speaker of the House of Commons considers the estimate then transmits it to the President of the Treasury Board, who lays it before the House with the Government of Canada’s estimates for the fiscal year. The Standing Committee on Access to Information, Privacy and Ethics reviews and reports on the Office’s effectiveness, management and operations, and its operational and expenditure plans. The figures in this summary have not been audited. Complete audited financial statements will be available on the Office's website.

This report summarizes the Office’s work in administering the Conflict of Interest Act. That work includes compliance activities, education and outreach initiatives, and investigations. Tabling letters Dear Madame Speaker: I am pleased to submit to you the report 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, 2026, for tabling in the Senate. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Honourable Konrad W. von Finckenstein, C.M., K.C.Conflict of Interest and Ethics Commissioner Dear Mr. Speaker: I am pleased to submit to you the report 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, 2026, for tabling in the House of Commons. The report is deemed permanently referred to the House of Commons Standing Committee on Access to Information, Privacy and Ethics, under Standing Order 108(3)(h)(v). This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Honourable Konrad W. von Finckenstein, C.M., K.C.Conflict of Interest and Ethics Commissioner Commissioner's message I am pleased to submit to Parliament my annual report on the administration of the Conflict of Interest Act, as required by paragraph 90(1)(b) of the Parliament of Canada Act. In 2025-2026, the Commissioner's Office continued to follow a mandate-focused approach that supports three key objectives, within the framework of its five-year strategic plan. The first is to help elected and appointed officials manage their conflicts of interest so competent and qualified people can move in and out of public service without difficulty. We offer training and educational resources to help them understand and follow the rules, and give them confidential advice. People with experience outside of the public sector may face potential conflicts of interest because of their business relationships. In addition, anyone may have personal relationships, social connections or investments that could create conflicts of interest. We identify such conflicts by reviewing public office holders' personal and financial information. Where needed, we work with them to implement conflict of interest screens so they can avoid dealing with files that could put them in a conflict of interest. The Act also requires recusal: public office holders must leave the room, physically or virtually, if there's a discussion, decision, debate or vote in which they have a conflict of interest. A second objective is to review and report on allegations of conflict of interest. When we receive information that someone may have contravened the Act, we may open a case file to review it. If there are reasonable grounds to believe there was a contravention, we will investigate. While not all case files result in investigations, and not all investigations result in reports, enforcing the Act is a core part of our mandate. Everything we do ultimately supports a third key objective: helping Canadians trust that the actions of elected and appointed federal officials are free from conflicts of interest. The Act includes transparency requirements, and the Commissioner's Office reports to Parliament and releases public reports. We also share as much information as we can through our website and when responding to requests for information. The April 2025 general election resulted in high turnover among elected and appointed officials, and more compliance work for the Commissioner's Office. We supported hundreds of Members of the House of Commons, ministers, parliamentary secretaries, and others in meeting their initial compliance requirements. I participated in a review of the Act conducted by the House of Commons Standing Committee on Access to Information, Privacy and Ethics, and pointed out the need to update the Act. Going forward, we will continue to follow our mandate-focused approach. We remain flexible and ready to respond to new challenges. Vision, mission, and mandate Vision To safeguard public confidence in the integrity of Parliament and government institutions. Mission To help elected and appointed public officials avoid conflicts of interest. Mandate Administer the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act to manage conflicts of interest and safeguard public trust. Helping appointed officials manage conflicts of interest A key objective of the Commissioner's Office is to help people appointed to federal positions manage potential conflicts between their public duties and private interests, so the most competent and qualified people can move in and out of public service without conflicts of interest. Avoiding conflicts of interest is one of four focus areas in its 2025-2030 strategic plan. Each focus area is a framework for purposeful projects and initiatives, and the plan itself is reviewed every year. Activities in this focus area include simplifying compliance processes, giving public office holders clear and consistent advice, and offering education and training that meets their specific needs. When a public official has competing interests that could interfere with their ability to be fair and objective when doing their job, their judgment could be affected by the possibility of benefitting themselves or someone they know. The Conflict of Interest Act aims to prevent that from happening. Under the Act, public officials are in a conflict of interest when they exercise an official power, duty or function that provides an opportunity to further their private (mostly financial) interests or those of their relatives or friends, or to improperly further another person's private interests. The Commissioner's Office helps public office holders ensure their actions, while performing their official duties and functions, are free from conflicts of interest. This makes it easier for experienced and competent people to move in and out of public office, in keeping with two of the Act's purposes: To encourage experienced and competent people to seek and accept public office To facilitate interchange between the private and public sectors Who is subject to the Act The Commissioner's Office helps appointed public officials avoid conflicts of interest by administering the Conflict of Interest Act. The Act applies mainly to federal officials appointed to their positions by the Governor in Council (the Governor General acting on the advice of Cabinet) or a minister. They are referred to collectively as “public office holders." Some of them must follow only the Act's general conflict of interest rules and some of its post-employment rules. These public office holders without reporting obligations are mostly part-time members of federal boards, commissions and tribunals, and ministerial staff who work on average less than 15 hours a week. The rest must also follow the Act's additional reporting and public disclosure rules, and its prohibitions against engaging in outside activities and holding what the Act calls “controlled assets." These reporting public office holders are mostly full-time. They include ministers, ministers of state (who may be called “secretaries of state"), parliamentary secretaries, ministerial staff who work on average 15 hours or more a week, and some senior public servants. Compliance with the Act is a condition of someone's appointment or employment as a public office holder (section 19). The Commissioner's Office helps them comply with the Act so they can more easily move in and out of public office. Figure 1: Snapshot of public office holders on March 31, 2026 Reporting public office holders Public office holders without reporting obligations 38 ministers 39 parliamentary secretaries 10 secretaries of state 683 ministerial staff 564 people appointed to other positions 1,512 part-time members of federal boards, commissions and tribunals, and some part-time ministerial staff 1,3341,512 The number of public office holders goes up and down during the year when new appointments are made and others end. Turnover may be especially high in an election year among ministers, parliamentary secretaries, and ministerial staff. The Commissioner's Office tracks these changes in its quarterly statistical reports. Figure 2: Turnover among public office holders in 2025-2026 Newly appointed or reappointedLeft officeReporting public office holders326518Public office holders without reporting obligations309173Total635691 There was a high turnover among appointed officials, including ministerial staff, after the April 2025 election. Although the number of ministerial staff ended at about the same level as the previous fiscal year, it rose by 50% between the first and last quarters of 2025‑2026. Figure 3: Turnover by quarter in 2025-2026 Q1Q2 Q3 Q4 Reporting public office holders1,0691,2821,2891,334Public office holders without reporting obligations 1,7431,5551,5261,512New and reappointed public office holders132192156155Public office holders who left office275179124113 Anyone appointed to public office may face potential conflicts of interest because of their family and social connections, business and professional relationships, and financial investments. Their private interests and those of their friends or family could be affected by decisions they might be called on to make or participate in. The more experience people have outside of government, the more likely they will have such conflicts. The Commissioner's Office helps public office holders identify and manage potential conflicts of interest by making sure they understand the Act's rules, guiding them on how to submit required information, and advising them on how to follow the rules. It also helps them put in place measures to avoid conflicts of interest if needed. Personal confidential advice The Commissioner's Office assigns each reporting public ​office holder an advisor to help them understand and follow the rules, and to guide them on meeting the Conflict of Interest Act's reporting requirements. They can at any time ask their advisor for confidential advice tailored to their personal situation. Public office holders without reporting obligations are not assigned their own advisor, but are encouraged to reach out to the Office to speak to an advisor at any time and get confidential, personalized advice. When asked, the Commissioner's Office explains the Act's requirements to candidates for federal appointments. It helps them better understand, before their appointment, the Act's restrictions on assets and outside activities and its post-employment rules. Figure 4: Advice by topic in 2025-2026 Gifts or other advantages​​239Outside activities282Material changes386Post-employment506General obligations638Total2,051 The Commissioner's Office tracks the topics public office holders ask about every quarter (three-month period) and updates its training and communications to focus on those topics. Requests for advice often reflect what is being talked about in the news. For example, in the lead-up to an election, the Commissioner's Office receives more requests for advice about post-employment. After an election, it gets more questions about general obligations and disclosures. The advice the Commissioner's Office gives individual public office holders is confidential. It will not share that advice with anyone else or make it public unless the public office holder formally asks it to. The public office holder is not bound by the same confidentiality requirements. They are free to share information about any advice they receive from the Commissioner's Office. Compliance measures There are some things the Conflict of Interest Act does not allow reporting public office holders to do, because of the potential for conflicts of interest. They include holding what it calls “controlled assets." However, the Commissioner may allow reporting public office holders who are not ministers or parliamentary secretaries to keep some controlled assets. These must be of such minimal value (up to $60,000) that they do not pose any risk of conflict of interest in relation to their official duties and responsibilities. What are controlled assets? Assets whose value could be directly or indirectly affected by government decisions or policy, like publicly traded securities (investments that are bought and sold on a public stock exchange). The Commissioner's Office works with public office holders to implement what the Act (part II) calls compliance measures. These are preventive mechanisms that can help them avoid conflicts of interest. Compliance measures include recusals, conflict of interest screens, and blind trusts. Rec​usals Recusal—leaving the room, physically or virtually, when there is a discussion, decision, debate or vote on a matter in which a public office holder has a conflict of interest—is the best way to manage and resolve such conflicts when they arise. Ministers and parliamentary secretaries may abstain instead of recusing in the House of Commons. This means they do not have to leave the Chamber or committee room. Instead, they may stay and simply observe. When a public office holder has recused to avoid a conflict of interest, the Commissioner's Office posts the recusal in the public registry. Figure 5: Recusals in 2025-2026 Recusals23Individuals who declared a recusal15 Conflict of interest screens If a public office holder is highly likely to be involved in discussions or decisions on a matter in which they would have a conflict of interest, the Commissioner's Office can help set up a conflict of interest screen. Figure 6: Conflict of interest screens for public office holders Existing screens on March 31, 202659New screens implemented in 2025-202623 A conflict of interest screen is a formal plan that is set up ahead of time to help a public office holder avoid handling files that could put them in a conflict of interest. The screen administrator (someone from their department or organization who is tasked with managing the screen) will make sure that matters related to the conflict of interest described in the screen are not brought to their attention. They will also be kept out of any discussions or decisions about those files. The screen administrator will give the files to other people to handle instead. Where possible, those people should be at the same level as the public office holder. If a matter that should have been caught by the screen—or any other matter in which they have a conflict of interest—does come before the public office holder, they must recuse. The screen administrator's job is to prevent conflicts of interest, and they can ask the Commissioner for confidential advice if needed. The Commissioner's Office posts conflict of interest screens in the public registry. Blind trusts If a reporting public office holder owns any controlled assets when they are appointed, they must divest (get rid of) them within 120 days by: selling them in an arm's-length transaction (where there is no special or close connection between them and the buyer), or putting them in a blind trust (transferring them to someone to hold and manage so they do not know how their money is being invested). The public registry includes a description of each controlled asset divested and the method used to divest it (sale or blind trust). A blind trust is a type of trust (a property interest held by one person for the benefit of another) in which the trustee manages the assets for the benefit of the reporting public office holder. The trustee is empowered to administer those assets without any input from the reporting public office holder, and may not give them any information about the trust's day-to-day operations. The terms and conditions of the blind trust agreement must meet the requirements set out in the Act. Trustees may be public trustees, public institutions like trust and investment companies and banks. That is the case for 55% of current blind trusts set up under the Act. Or, trustees may be individuals like lawyers and chartered accountants. That is the case for 45% of current blind trusts under the Act. The Commissioner must be satisfied that there is an arm’s-length relationship between a reporting public office holder and their trustee. In 2025-2026, the Commissioner's Office oversaw 58 divestments by sale and blind trust. The Commissioner's Office can help reporting public office holders get reimbursed (paid back) for the costs of setting up, administering and dismantling a trust, selling their assets, or withdrawing from activities. In 2025-2026, it issued 182 reimbursement orders totalling $1,681,187. The number of blind trusts has remained steady over the past three years with an average of 81 active blind trusts a year. Over 75% of blind trusts were created for Governor-in-Council appointees. About 12% were for ministers and parliamentary secretaries, and 13% were for ministerial staff. Compliance measures help public office holders avoid conflicts of interest. The table below identifies how some of these mechanisms work together. Compliance mechanismDescriptionRecusalThe public office holder leaves the room and withdraws from discussions, decisions, or meetings where they have a conflict of interest.Conflict of interest screenAn administrative process, managed through staff or senior officials, that prevents public officials from being aware of files in which they have a conflict.Blind trustA public office holder places their assets under the control of an independent trustee and has no knowledge of or involvement in how the trustee manages those assets. Figure 7: Annual average of compliance measures over the past five years Five-year yearly averageBlind trusts established 16 Screens established 21Recusals31 Education and training The Commissioner’s Office offers public office holders and the staff who support them flexible and accessible learning opportunities to help them understand the Conflict of Interest Act’s rules and other requirements. These include live online and in-person training, interactive learning tools, and targeted educational sessions for groups of public office holders and their support staff. They are part of an outreach strategy that the Commissioner’s Office continually updates to reflect current information needs and emerging trends. When public office holders are first appointed and during their time in office, the Commissioner’s Office sends them information that explains the rules they must follow. In 2025-2026, it explained the rules to 247 public office holders. It also invites them to attend educational sessions focused on their obligations under the Act. When they are getting ready to leave public office, the Commissioner’s Office gives them information about the Act’s post-employment rules. Educational sessions In 2025-2026, the Commissioner’s Office held 39 educational sessions on the Act. Some were regularly scheduled sessions, including several for newly appointed public office holders. Others were delivered in response to requests from government agencies, boards or tribunals whose members are subject to the Act. To meet participants’ learning needs, the Commissioner’s Office refines the content to address popular questions about specific issues. To accommodate their schedules, it delivers sessions at different times of day. In 2025-2026, for example, it offered some during evening hours. Training modules The Commissioner’s Office developed two training modules on the Act in 2025-2026: one is for public office holders without reporting obligations, the other is for reporting public office holders. Both are online, self-directed courses that include real-life scenarios and interactive elements. They help participants understand their obligations and reporting requirements, how to manage potential conflicts of interest, and when to seek guidance. The modules are publicly available and can be accessed through the Office’s website. Guidance on reporting requirements Under the Conflict of Interest Act, reporting public office holders must give the Commissioner's Office a lot of personal and financial information for themselves and their family members. Most of it is kept private, but some is posted in the public registry as required by the Act. The Act's initial and ongoing reporting requirements support transparency—a key objective of the Act. It also ensures the Commissioner's Office gets the information it needs to help reporting public office holders avoid conflicts of interest. When a reporting public office holder is appointed or reappointed, the Commissioner's Office guides them on what they need to report and when. Each reporting public office holder must complete an initial compliance process within 120 days after they are appointed. It includes one-on-one meetings with their assigned advisor at the Commissioner's Office that are an opportunity to: walk through the Act's rules in detail understand how the requirements apply to their specific duties explore the nuances of their file or circumstances clarify expectations and reporting timelines ask questions in a confidential environment. The initial compliance process starts with each reporting public office holder filling out a Confidential Report. The Commissioner's Office reviews it and advises them on how to organize their affairs to comply with the Act and avoid conflicts of interest. It then prepares all required public declarations for them to review, approve, and return. Approved declarations are posted in the public registry. While in public office, reporting public office holders must meet ongoing reporting requirements, within certain deadlines. They must tell the Commissioner's Office about the following things, some of which are made public: Material changes (any changes to the information in their Confidential Report). Gifts or other advantages with a value of $200 or more that they or their family members accept, and multiple gifts received from one source in a 12-month period with a total value of $200 or more. Travel on non-commercial chartered or private aircraft accepted by ministers, ministers of state or parliamentary secretaries for themselves, members of their family, or ministerial staff or advisers. Recusals (when they stepped away from a discussion, decision, debate or vote on any matter in which they might have a conflict of interest). Firm offers of outside employment (does not include jobs or contracts with federal government entities or federal parliamentary entities). Acceptance of offers of outside employment. Figure 8: Public declarations by reporting public office holders added to the public registry in 2025-2026 Agreed compliance measures*​23Declarable assets143Gifts or other advantages221Liabilities94Outside activities99Recusals23Summary statements for initial compliance323Travel2Post-employment exemptions, waivers or reductions3Other1 Total932 *Agreed compliance measures are mostly comprised of conflict of interest screens. There was an 11% increase in public declarations from the year before. That is because more initial compliance processes, which include public declarations, were completed. Each yea​​r, reporting public office holders must go over their information with the Commissioner’s Office, and update it as needed. It completed over 650 annual reviews in 2025-2026.​ Figure 9: Compliance processes completed in 2025-2026 Initial com​pliance processes 327Annual reviews658 Reviewing and reporting on alleged conflicts of interest Enforcing the Conflict of Interest Act is a core part of the Commissioner's mandate. It is captured in one of the key objectives of the Commissioner's Office: to review and report on allegations of conflict of interest involving elected and appointed officials. It also relates to a focus area of the Commissioner's Office strategic plan: avoiding conflicts of interest. Enforcing the Act provides transparency and accountability. It includes investigating possible conflicts of interest, addressing non-compliance with reporting deadlines, and reporting on matters referred by the Public Sector Integrity Commissioner. Penalties The Commissioner can impose administrative monetary penalties of up to $500 on reporting public office holders who fail to meet certain reporting deadlines in the Conflict of Interest Act. Penalties are posted in the public registry. The aim is to encourage compliance rather than to punish. Penalties underscore the importance of meeting the Act's reporting requirements. Timely and accurate filing of information helps the Commissioner's Office identify potential conflicts of interest and advise public office holders on how to avoid them. It also supports transparency. There are penalties for missing reporting deadlines. The Commissioner issues a penalty when a reporting public office holder fails to respond to repeated communications and appears to be generally uncooperative. Non-compliance is rarely deliberate, and the involvement of the Commissioner's Office usually solves the issue. In 2025-2026, the Commissioner issued eight penalties. Administrative monetary penalties One $200 penalty for failing to submit a Confidential Report within 60 days of appointment. One $200 penalty for failing to provide, within 60 days of appointment, as part of the Confidential Report, all information that the Commissioner considers necessary to ensure compliance with the Act. One $200 penalty for failing to provide a confirmation of sale or a copy of a contract or other instrument establishing a trust in respect of divestment of controlled assets. Two $200 penalties for failing to sign a Summary Statement within 120 days of appointment. Three $200 penalties for failing to disclose a material change relating to assets. Compliance orders Under section 30 of the Act, the Commissioner may order public office holders to do or stop doing something in order to comply with the Act, like submit documents for an annual review, divest controlled assets, or quit prohibited activities. Compliance orders are posted in the public registry. The Commissioner did not issue any compliance orders in 2025-2026. Investigations The Commissioner can investigate public office holders when he has reasonable grounds to believe they may have contravened the Conflict of Interest Act. He can start an investigation (called an examination) under the Act in one of two ways: When asked to investigate by a Senator or a Member of the House of Commons. They must provide reasonable grounds to believe that someone has contravened the Act. The Commissioner's Office received 4 examination requests from Members in 2025-2026. On his own initiative if he has reason to believe that someone may have contravened the Act. Decisions to investigate may be based on information from media reports or complaints from members of the public, among other sources. The Commissioner's Office received 26 examination requests from members of the public in 2025-2026. The Commissioner reports publicly on investigations. This supports transparency and accountability. Examination reports are also educational tools that can help prevent future contraventions of the Act. No examination reports were issued in 2025-2026. The Commissioner discontinued one examination without publishing a report. The allegation was that a former ministerial staffer had communicated with their former minister about a client's application for funding from their department. The evidence gathered during the examination from the subject and other witnesses did not support the allegation. Case files The Commissioner's Office opens a case file if it becomes aware of a concern or an allegation that someone may have contravened the Act. This does not mean it is investigating, but is simply reviewing the matter to determine if there are grounds to investigate. Most case files result from communications from members of the public, often on the basis of information from news articles. Concerns sometimes originate within the Office. In addition to considering the information provided by the complainant, if there is one, it gathers and reviews all relevant information from public sources, and information from its confidential disclosure files that could relate to the matter. This is called an initial review. The Commissioner does not have powers to compel testimony or documents from witnesses during an initial review. These powers apply only when an examination has been launched. Not all case files result in examinations. The Commissioner will investigate only if he finds that an examination is warranted. If he finds an examination is not warranted, the case file is closed. Referrals from the Public Sector Integrity Commissioner The Public Sector Integrity Commissioner may refer matters to the Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act. Under section 68 of the Conflict of Interest Act, the Commissioner must issue a public report on each referral, whether he decides to investigate or not. The Commissioner received one referral from the Public Sector Integrity Commissioner in 2025-2026. Case files (a case file is a concern or allegation reviewed by the Commissioner's Office) Total case files: 24 Ongoing: 4 Closed without an examination: 20 Closed with publication of report: 0 Figure 10: Breakdown of case files in 2025-2026​​ Subject of each case fileCurrent or former minister or parliamentary secretary4Current or former public office holder20Source of these case files ​Member of the House of Commons1Office of the Public Sector Integrity Commissioner1Media0Member of the general public21Within the Office1Nature of the concern*Furthering a private interest (subsection 6(1) of the Act)12Duty to recuse (section 21)​1Post-employment rules (sections 33 to 35)5Influence (section 9)8Preferential treatment (section 7)5Prohibited activities (section 15)14 *A case file can have more than one concern Fostering public confidence Helping Canadians trust that the actions of elected and appointed federal officials are free from conflicts of interest is a key objective of the Commissioner's Office. In fact, everything it does ultimately supports this objective, including projects and activities in three focus areas identified in its strategic plan: Avoiding conflicts of interest – Communicating clearly and accessibly about the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons to support transparency and accountability. User-friendly experience – Ensuring that public office holders have positive interactions with the Commissioner's Office so they feel comfortable asking for advice when faced with potential conflicts of interest. Tools, knowledge and skills – Making sure employees have what they need to fulfill the Commissioner's mandate effectively. As an independent, non-partisan entity, the Commissioner's Office is well placed to ensure impartial oversight, prevent political interference, and promote accountability. Supporting transparency The Commissioner's Office is as open as possible with Parliament and Canadians. That is because transparency is key to public trust. When information is shared, people can see that the rules are being followed. Transparency is built into the Conflict of Interest Act through its public declaration requirements. Some of the information that reporting public office holders must give the Commissioner's Office is posted in the public registry. Transparency is balanced by the Act's confidentiality provisions, which encourage public officials to communicate freely and openly with the Commissioner's Office. The Commissioner's Office respects this balance. When asked to share or comment on confidential matters, it directs those who ask to the public registry. Public registry A searchable database that can be accessed through the Office’s website, the public registry contains all the information about current Members that the Commissioner is allowed to share. Figure 11: Public registry postings and views Postings Views2025-20261,248190,000Five-year average1,260126,900 Reporting public office holders' information stays in the registry until the end of their post-employment cooling-off period. The public registry was accessed 520 times a day on average in 2025-2026. It tends to get more visitors when an issue about someone's disclosures comes up in the media, or if the Commissioner's Office has posted information in the registry about a high-profile official. Reporting to Parliament The Commissioner has a duty to report to Parliament, testify before parliamentary committees, and answer questions from Parliament. As an independent Officer of the House of Commons, he reports to Parliament directly, not through a minister. By June 30 each year, the Commissioner sends a report on the administration of the Conflict of Interest Act to the Speakers of the Senate and the House of Commons for tabling. The Commissioner's Office sends communiqués to parliamentarians about its reports and other activities. It sent seven of these in 2025-2026. The House of Commons Standing Committee on Access to Information, Privacy and Ethics has oversight responsibility for the Commissioner's Office. The Committee reviews its annual spending estimates, and matters related to the Commissioner's reports under the Act. Figure 12: Committee appearances in 2025-2026 September 15, 2025 House of Commons Standing Committee on Access to Information, Privacy and Ethics Briefing session with the Conflict of Interest and Ethics Commissioner Commissioner von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance Melanie Rushworth, Director, Communications, Outreach and Planning​ October 30, 2025 House of Commons Standing Committee on Procedure and House Affairs (in camera) Forms and guidelines under the Conflict of Interest Code for Members of the House of Commons Commissioner von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance Michael Aquilino, Legal Counsel December 8, 2025 House of Commons Standing Committee on Access to Information, Privacy and Ethics Review of the Conflict of Interest Act Commissioner von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance Michael Aquilino, Legal Counsel The Commissioner participated in a review of the Conflict of Interest Act conducted by the Standing Committee on Access to Information, Privacy and Ethics. In public hearings held from September 24 to December 8, 2025, the Committee heard from 23 expert witnesses from the academic community, business, and government, including representatives of the Commissioner's Office. While many pointed to the strengths of the Act, which has been held up as a model internationally, some also identified possible improvements. The Committee presented an interim report to the House of Commons on November 28, 2025. The Commissioner appeared before it to discuss related matters before the review started, and again as the hearings ended. He noted that the Act has been working well since it took effect in 2007 and has met the purposes set out in section 3, but said its administration could be made more efficient. The Commissioner proposed five amendments that reflect the experience of the Commissioner's Office in administering the Act for almost two decades. They are described in the 2024-2025 Annual Report under the Act. Public communications The Commissioner's Office shares as much information as it can with the public, and in different ways, under the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. It posts information on its website and on social media and responds to information requests from the media and members of the public. Figure 13: Website users and page views in 2025-2026 2025-2026Website users218,700Website page views366,500 In 2025-2026, the website attracted 70% more users and 30% more page views than the year before. The Commissioner's Office also continued to work with House of Commons IT Services on the development of a redesigned website. Figure 14: Social media presence in 2025-2026 X@EthicsCanada LinkedIn@ethics-ethique-canada Posts4244Followers4,4451,262 The Commissioner's Office uses social media to share information about its activities and updates from the public registry that may be of interest to journalists, academics, Canadian and international ethics practitioners, and others. Media inquiries in 2025-2026 Emails and phone calls from the media: 147 Over 80% were questions about a specific elected or appointed official, including questions about their public disclosures and compliance measures About 20% were general inquiries about the Office's role and mandate and activities It responds to journalists and members of the public who seek information by explaining how the Act and the Code work, and by directing them to the public registry when appropriate. Public inquiries related to the Office in 2025-2026 Emails, letters, and phone calls from members of the public: 1,668 10% were general inquiries about the role of the Office. 75% were complaints about an elected or appointed official. Some were shared with the Investigations division for follow-up. Complaints are often based on observations made on the public registry or items that are discussed in the news. For example, this includes a coordinated email campaign describing an allegation against a minister. The Office responded to all 800+ emails by explaining that the minister's alleged behaviour was not covered by the Commissioner's mandate. 15% were general complaints about the activities of individuals that may not have been subject to the Act or the Code, about Members' floor crossings and behaviour in the House of Commons, and their use of social media. The Commissioner's Office received three times more public inquiries than in the previous year. This increase is likely due to the email campaigns mentioned above. Most of these inquiries were not directly related to the Office's mandate and the senders are informed that their concerns will not be acted on. Nevertheless, responding to these inquiries allows the Office to further explain how the rules work and are applied. The Commissioner's Office is transparent about what it does. For example, it publishes quarterly statistical reports that contain data on its activities, and tracks how it meets its service standards: Contact new or reappointed public office holders within 3 business days Respond to public office holders' requests for advice within 3 business days Answer media inquiries within 4 hours Answer inquiries from other members of the public within 10 business days It met all these service standards for 2025-2026 as a whole. Connecting with others The Commissioner's Office works with other organizations to stay updated on and share best practices. This supports its objective of fostering public confidence that elected and appointed officials' actions are free from conflicts of interests. Participation in these networks helps it strengthen its internal expertise. It continues to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN) of federal, provincial, and territorial conflict of interest commissioners. In September 2025, the Commissioner, the Director of Communications, Outreach and Planning and another Office representative attended CCOIN's annual meeting, hosted by Conflict of Interest Commissioner Victoria Gray in Victoria, British Columbia. Commissioner von Finckenstein and Senate Ethics Officer James O'Reilly will welcome CCOIN commissioners to Ottawa in September 2026. The Réseau francophone d'éthique et de déontologie parlementaires (RFEDP) promotes exchanges between parliaments and entities in the Organisation internationale de la Francophonie [link in French only] that are interested in ethics and codes of conduct. The Commissioner's Office is a founding and active member. RFEDP activities in 2025-2026: At the RFEDP's Annual General Assembly held in Paris in July 2025, the Commissioner's Office was appointed Vice‑President of the RFEDP Bureau. Its representative for the post is the Director of Communications, Outreach and Planning. Throughout the year, the Commissioner's Office contributed to the Bureau's regular meetings and supported the integration of new members. It strengthened its leadership role in the RFEDP by creating a workshop called “Developing ethical and deontological reflexes." This training supports member countries in addressing common parliamentary ethics challenges. It delivered the online workshop to Burundian parliamentarians in June 2025 and collaborated with several RFEDP partners—among them the School of Advanced Political and Legal Studies and Professor Charles Moumouni (Laval University)—to tailor the content to diverse national contexts. A second, more interactive version of the workshop was delivered to parliamentarians and academics in the Democratic Republic of Congo in February 2026. The Commissioner's Office actively participated in RFEDP-led sessions on the exchange of best practices. The Commissioner's Office is part of the Council on Governmental Ethics Law (COGEL), an international network of professionals working in government ethics, lobbying regulation, elections administration, campaign finance, and freedom of information. COGEL promotes integrity and transparency in government by supporting training, professional development, and the exchange of expertise among practitioners from different jurisdictions. Representatives of the Commissioner's Office attend COGEL's annual conference and participate in virtual activities throughout the year. These events are opportunities to exchange knowledge and collaborate with counterparts working in conflict of interest and related fields. In 2025-2026, the Commissioner's Office shared its expertise when representatives participated as speakers on two panels at the COGEL conference. Managing the Commissioner's Office The administration of the Conflict of Interest Act is supported by the employees, policies and processes of the Commissioner's Office. The need to continually maintain and strengthen this infrastructure is reflected in two focus areas of its strategic plan: Healthy and fulfilling workplace – Activities include keeping employees engaged and motivated, promoting inclusivity and equity, and respecting and supporting bilingualism. Tools, knowledge and skills – Activities include offering employees comprehensive training, implementing coherent information management practices, and facilitating the sharing of expertise. A team of 51 employees supports the Commissioner. They have expertise in areas like compliance, law, communications, corporate management, investigations, and parliamentary relations. The Commissioner provides overall direction and makes the decisions that need his input and approval. He works closely with other members of the Office's Senior Management Committee. Commissioner Konrad von Finckenstein (centre) with (from left to right): Martine Richard, Senior General Counsel, Investigations and Legal Services Sandy Tremblay, Director, Corporate Management Lyne Robinson-Dalpé, Director, Advisory and Compliance Melanie Rushworth, Director, Communications, Outreach and Planning Lyne Robinson-Dalpé retired in the last quarter of 2025-2026 after more than 20 years of dedicated service to the Commissioner’s Office in a 35-year career of public service. Lisa DeMoor has now joined the Office as Director, Advisory and Compliance. Under the Commissioner's leadership, employees handle the daily tasks of administering the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. They make sure the processes and structures are in place to support their administration. These include strong internal controls to manage public money responsibly, protect public assets, and use resources in an effective and efficient way. An independent auditor reviews the Office's financial statements every year. Financial information for 2025-2026 is outlined in the Appendix. Accessibility Office employees also work on other important files like compliance with the Accessible Canada Act. In December 2025, the Commissioner's Office released its second accessibility plan, for the 2025 to 2028 period. The updated plan builds on its 2024 progress report and incorporates best practices from its 2023-2025 accessibility plan. It outlines commitments to remove barriers across all priority areas under the Accessible Canada Act, and introduces new elements like culture, SMART objectives, and enhanced consultation processes. Supporting bilingualism In 2025-2026, the Commissioner's Office reviewed and updated its Policy on Official Languages. The language requirements assigned to positions reflect employees' duties and work units, and obligations under the Official Languages Act related to service to the public and language of work. All term and indeterminate positions designated as bilingual are staffed with individuals who have the required linguistic profile. The Commissioner's Office actively offers communications and services in both English and French. In particular, it: gives members of the public a clear choice to communicate in their preferred official language when initiating contact with them, and continues communications in the language chosen by the member of the public. The Commissioner's Office makes the English and French versions of all written communications to the public available at the same time, and ensures they are of equal quality, no matter what communication method it uses. Information management The Commissioner's Office follows information management practices that include destroying its files on former public office holders who have been in post-employment under the Conflict of Interest Act for more than 10 years. It identifies all internally held files of individuals who have passed this 10-year limit. Then it deletes their electronic information from the Office's records management system. If there are physical files, it shreds them. Training The Commissioner's Office makes sure employees get the right training so they have the knowledge and skills to do their jobs and help fulfill its mandate. In 2025-2026, it started refining its onboarding process, which is designed to welcome new employees and give them clear, practical guidance from the moment they join the Commissioner's Office. It brings together what they need to know about their role, the Commissioner's mandate, and how the Office works day-to-day, so they can contribute to a healthy, respectful and effective workplace. Step‑by‑step checklists, orientation activities and follow‑up milestones help ensure each employee has the tools, knowledge and support they need to succeed in their new position, and feels part of the Office's mission from the start. The Commissioner's Office offers employees ongoing training on systems and tools, and occasional training on policies and procedures. For example, in March 2026, harassment and violence prevention training was provided to all employees. Each year, the Commissioner's Office identifies job-specific training opportunities in employees' individual learning and development plans. It also promotes the sharing of expertise, including soft skills, within the Office and through employees' active participation in external knowledge groups. Crisis communications plan In September 2025, the Senior Management Committee adopted a crisis communications plan. It identifies several scenarios that would require a crisis communications approach. Staffing To make sure it has the right positions and the right people in them to support its mandate, the Commissioner's Office ran seven staffing processes in 2025-2026. In June, it submitted its first Pay Equity Annual Statement to the Office of the Pay Equity Commissioner. Legal developments The Commissioner's decisions on investigations are sometimes challenged in court. Dealing with these cases can help clarify the Commissioner's mandate and powers. One court case was underway in 2025-2026. Democracy Watch had asked the Federal Court of Appeal to review former Commissioner Mario Dion's findings in the 2021 Trudeau III Report. He had concluded that Prime Minister Justin Trudeau did not contravene the Conflict of Interest Act when the government chose WE Charity to run a COVID-19 program, even though some of his family members were closely involved in some of WE Charity's projects. The Commissioner determined that the Act only covers real or potential conflicts of interest, and a situation that simply appears to give rise to an appearance of conflict does not contravene the rules. The Federal Court of Appeal heard the matter on March 24, 2024. The Attorney General of Canada (it was named to respond to Democracy Watch's application for judicial review) argued that the application was based on grounds barred from judicial review by section 66 of the Conflict of Interest Act. Section 66 is a partial privative clause, which prevents an applicant from bringing an application for judicial review on questions of law and fact. On October 2, 2024, the Federal Court of Appeal dismissed Democracy Watch's application for judicial review. In December 2024, Democracy Watch filed an application for leave to appeal to the Supreme Court of Canada. Leave was granted on May 1, 2025. A full panel of the Supreme Court held hearings on January 14 and 15, 2026. The Court reserved judgment in the case and will publish its ruling later. Appendix: Financial resources summary (thousands of dollars) Program Activity 2024-2025 2025-2026Alignment to Government of Canada OutcomesActual Spending ​Main Estimates ​Total Authorities ​Actual Spending Administration of the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons 7,594 8,152 8,152 7,984 Government Affairs Contributions to employee benefit plans 939 1,013 1,013 960 Total spending 8,533 9,165 9,165 8,944 Plus: cost of services received without charge 918 N/A N/A 998 Net cost of department 9,451 9,165 9,165 9,942 The Office of the Conflict of Interest and Ethics Commissioner’s budget process is set out in the Parliament of Canada Act. Before each fiscal year, the Office prepares an estimate of its budgetary requirements. The Speaker of the House of Commons considers the estimate then transmits it to the President of the Treasury Board, who lays it before the House with the Government of Canada’s estimates for the fiscal year. The Standing Committee on Access to Information, Privacy and Ethics reviews and reports on the Office’s effectiveness, management and operations, and its operational and expenditure plans. The figures in this summary have not been audited. Complete audited financial statements will be available on the Office's website.

The Commissioner can start an investigation (called an inquiry) under the Conflict of Interest Code for Members of the House of Commons in one of three ways: When asked to investigate by a Member of the House of Commons who has reasonable grounds to believe another Member has contravened the Code.When directed to by the House of Commons. (This hasn’t happened yet.)On his own initiative if he believes, based on information from various sources, including media reports and complaints from members of the public, that someone may have contravened the Code. When the Commissioner finishes an inquiry, he sends a report to the Speaker of the House of Commons. That report is also made public.

The Commissioner’s Office can investigate people covered by the Conflict of Interest Act and/or the Conflict of Interest Code for Members of the House of Commons: Elected Members of ParliamentMinistersParliamentary secretariesMinisterial staffPeople appointed to their positions by the Governor in Council (the Governor General acting on the advice of the Cabinet), such as members of federal boards, commissions and tribunals, and some senior public servants It can investigate matters covered by the Act and the Code, which deal specifically with conflicts of interest. The Act and the Code aim to ensure that elected or appointed federal officials do not use their positions to: further their private interests,further the private interests of family members (and friends, in the case of the Act), orimproperly further the private interests of anyone else. What don’t we investigate? The Commissioner’s Office cannot investigate anyone who is not covered by the Act or the Code. They include: Most federal public servantsMost employees of federal Crown corporationsMembers’ staffPolitical partiesProvincial and territorial officialsMunicipal officialsCompanies and other organizations in the private sector The Commissioner’s mandate is about conflicts of interest within the meaning of the Act and the Code. It does not cover every kind of ethical issue. For example, unless a specific rule in the Act or the Code appears to have been broken, we don’t investigate complaints about: How Members of the House of Commons communicate with their constituents, behave in the House of Commons, or spend their parliamentary budgetsHow a federal department or organization has treated somebodyHow a provincial or territorial department or organization has treated somebodyIssues involving criminal or civil law, including family lawMatters of government policy

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Fourth quarter (January to March) – Overview of statistical data and conflict of interest compliance for MPs and public office holders. Fourth quarter of fiscal year 2025-2026 – January to March 2026 Individuals subject to conflict of interest regimes 340Members of the House of Commons1,334Reporting public office holders1,324Public office holders without reporting obligations (87 ministers and parliamentary secretaries, 683 ministerial staff,564 people appointed to other positions) (part-time members of federal boards,commissions and tribunals,and some part-time ministerial staff) Members of the House of Commons are elected. Public office holders are appointed. Conflict of interests prevention The Office helps Members of the House of Commons and Public office holders prevent conflicts of interests by: Members of the House of CommonsPublic office holdersContacting them as soon as they take office0 times 155 times Ensuring they complete the initial compliance process110 process215 processesGiving them advice107 times506 timesFollowing up with them every year0 reminders222 remindersPosting information in the public registry133 times195 timesTelling them about the post-employment rulesN/A52 times 48% of new reporting public office holders met all deadlines. The Office contacted new public office holders and MPs within 3 business days in 87% of cases. Confidential advice When a Member or a public office holder has questions, they ask advisors at the Office for confidential advice. Members received advice 107 timesPublic office holders received advice 506 timesGeneral obligations: 28%General obligations: 32%Material changes: 30%Material changes: 21%Gifts and other benefits: 28%Post-employment obligations: 25%Letters of support and fundraising: 14%Outside activities: 12% Gifts or other advantages: 10% The number of requests for advice was higher than the last quarter. The Office responded to standard requests within 3 business days in 90% of cases. Public registry The Office added information to the public registry: Members of the House of CommonsPostingsPublic office holdersPostingsDisclosure summaries 105Agreed compliance measures5Gifts and other benefits 5Assets27Material changes 8Gifts or other advantages43Sponsored travel15Liabilities8Private interest0Outside activities23Total133Recusals3 Summary statements81 Travel1 Other0 Total191 The volume of postings was higher compared to the last quarter. The public registry is updated daily and can be accessed online.You can search it by date, type of declaration, regime, or an individual's name.The information in the registry is the only information the Office can make public. 8,500 public registry visitors 36,000 public registry views After a Member leaves office, their information is removed from the registry. Post-employment rules (Conflict of Interest Act only) All public office holders are subject to some rules even after they leave their position. 113 public office holders left office this quarter Former reporting public office holders face extra rules for one or two years after they leave office (cooling-off period) 740 former public office holders were in their cooling-off period They can ask for an exemption, waiver, or reduction of their cooling-off period 1 exemption, waiver, or reduction granted Sanctions (Conflict of Interest Act only) 4 notices of violation sent Reporting public office holders who miss a reporting deadline may have to pay an administrative monetary penalty (fine). Before issuing a penalty, the Office sends them a notice of violation. Administrative monetary penalties One $200 penalty for failing to submit a Confidential Report within 60 days of appointment. One​ $200 penalty for failing to provide,​ within 60 days of appointment, as part of the Confidential Report, all information that the Commissioner considers necessary to ensure compliance with the Act. One $200 penalty for failing to provide a confirmation of sale or a copy of a contract or other instrument establishing a trust in respect of divestment of controlled assets. ​One​ $200 penalty for failing to sign a Summary Statement within 120 days of appointment. ​ ​​​​​All penalties are posted in the public registry​. Investigations (Act & Code) Case files opened and closed (a case file is a concern that is reviewed by the Office) 11 case files0 reports published6 case files closed Subject of new case filesSource of new case files0 ministers or parliamentary secretaries8 members of the general public5 Member of the House of Commons3 Member of the House of Commons6 public office holders0 media 0 within the Commissioner's Office 0 Office of the Public Sector Integrity Commissioner The Office's target is to finish investigations in 12 months. Education and outreach Requests from the publicRequests from the mediaSocial media257 requests*48 media requests10 X posts 189 outside mandate0 interviews granted4,445 X followers68 within mandate5,700 media mentions 15,700 X mentions *See case files for investigation requests. 10 LinkedIn posts 1,262 LinkedIn followers WebsiteParliamentTraining and Education57,500 website visitors0 appearances14 presentations87,000 website views10% percentage of Question Periods where the Office was mentioned243 participants Responded to standard media requests within 4 hours in 100% of cases. Responded to standard public requests within 10 days in 96% of cases. To obtain the data used to produce this report, please contact us.

Report on former deputy minister of Immigration, Refugees and Citizenship Canada (IRCC) for exerting undue influence on IRCC senior management to hire a friend at a level for which he was not qualified. Preface The Conflict of Interest Act (Act), S.C. 2006, c. 9, s. 2, came into force on July 9, 2007. Pursuant to section 68 of the Act, if a matter is referred to the Conflict of Interest and Ethics Commissioner by the Public Sector Integrity Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act, the Conflict of Interest and Ethics Commissioner will commence an examination pursuant to subsection 45(1) of the Act if there is a reason to believe that a public office holder may have contravened the Act. Regardless of whether an examination is commenced or not, the Conflict of Interest and Ethics Commissioner must provide a report to the Prime Minister setting out the facts in question as well as the Commissioner's analysis and conclusions in relation to the referral. A copy is provided to the public office holder or former public office holder who is the subject of the report and to the Public Sector Integrity Commissioner. The report is also made public. Executive Summary This report presents the findings of an examination under the Conflict of Interest Act of the conduct of Christiane Fox while she was Deputy Minister of Immigration, Refugees and Citizenship Canada (IRCC). In a disclosure referred to me by the Public Sector Integrity Commissioner, it was alleged that Ms. Fox exerted undue influence on IRCC senior management to hire a friend at a level for which he was not qualified. The examination focused on section 9 of the Act. It prohibits public office holders from using their position to seek to influence another person's decision to further their own private interests or those of their relatives or friends, or to improperly further the private interests of another person. The evidence showed that in early March 2023, Björn Charles contacted Ms. Fox, whom he knew from when they were both athletes at the same university, about possibly working for IRCC. At Ms. Fox's invitation, he sent her his résumé. Ms. Fox spoke with her newly appointed Assistant Deputy Minister (ADM) about challenges in IRCC's division responsible for processing requests made under the Access to Information Act (the ATIP division). They discussed the need to modernize the ATIP division's client experience and to bring in a fresh perspective by hiring from outside government. Ms. Fox identified Mr. Charles as a candidate for the project manager position responsible for modernizing the ATIP division's client experience. She later sent the ADM his résumé. The process that led to Mr. Charles' eventual hiring included him meeting with the ADM and then with senior ATIP division officials. Ms. Fox asked Mr. Charles to keep her informed throughout the process and sought updates from departmental officials about his hiring. In one email, she suggested to the ADM that Mr. Charles should be offered a position at a higher level than departmental officials were proposing. Evidence showed they felt pressured to hire him at a level for which he was not qualified. Ms. Fox also communicated privately with Mr. Charles. To help him prepare for his interview with ATIP division officials, she sent him an internal IRCC briefing document. In late April 2023, Mr. Charles was hired for a casual position in the ATIP division at the higher level. In September of the same year, he was offered a one-year term position. In seeking to determine whether there was a contravention of section 9 of the Act, I first had to determine if Ms. Fox and Mr. Charles were friends. I found that, based on the nature and history of their past interactions, they are not friends within the meaning of the Act. I then had to determine whether Ms. Fox used her position as Deputy Minister to seek to influence departmental officials to hire Mr. Charles, and whether doing so was improper. Ms. Fox maintained that her involvement in the process was appropriate. She said hiring Mr. Charles would respond to challenges in IRCC's ATIP division and advance the objectives of the Call to Action on Anti-Racism, Equity, and Inclusion in the Federal Public Service. I did not find these claims credible. I concluded that Ms. Fox used her position as Deputy Minister to give Mr. Charles preferential treatment, by ensuring he met with departmental officials quickly, seeking updates about his hiring, giving him internal information, and pushing for a higher job classification. As the Commissioner's Office has noted in previous examination reports, giving someone preferential treatment is, in itself, improper. I therefore found that Ms. Fox contravened section 9 of the Conflict of Interest Act. Referral On May 26, 2025, the Office received from Harriet Solloway, Public Sector Integrity Commissioner, a referral dated April 2, 2025, regarding Christiane Fox, Deputy Clerk of the Privy Council, Associate Secretary to the Cabinet, and Deputy Minister of Intergovernmental Affairs at the time. The referral was made under subsection 24(2.1) of the Public Servants Disclosure Protection Act. Pursuant to section 68 of the Conflict of Interest Act, when a matter is referred to this Office by the Public Sector Integrity Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act, I must provide a report to the Prime Minister setting out the facts in question as well as my analysis and conclusions in relation to the referral. Ms. Fox, a reporting public office holder subject to the Conflict of Interest Act since June 12, 2017, held the position of Deputy Minister of Immigration, Refugees and Citizenship Canada (IRCC) from July 18, 2022, to January 26, 2024. According to Commissioner Solloway's letter, the discloser alleged that when Ms. Fox was Deputy Minister of IRCC, she exerted undue influence on senior management in her department to hire her friend from school and a manager of the gym her family attends and have him appointed at a level for which he was not qualified. Details in respect of these allegations were provided in the form of a report on an investigation conducted under the Public Servants Disclosure Protection Act by IRCC's Office of Internal Disclosure. One of the matters investigated by IRCC, as set out in that report, related to preferential treatment surrounding the appointment of Ms. Fox's alleged friend at IRCC. ​Concerns and process On June 10, 2025, I wrote to Ms. Fox informing her of the disclosure of an allegation of conflict of interest made against her in a referral from the Public Sector Integrity Commissioner. I informed Ms. Fox that I had reason to believe, based on the information contained in the Immigration, Refugees and Citizenship Canada (IRCC) report, that she may have used her position as Deputy Minister of IRCC to influence departmental officials into hiring Mr. Björn Charles, alleged to be her friend, or to improperly further Mr. Charles' private interests by influencing departmental officials to hire him for a position at a level for which he was not qualified, in contravention of section 9 of the Conflict of Interest Act (Act). As a result, I informed Ms. Fox that I was commencing an examination into her conduct. Section 9 of the Act prohibits public office holders from using their position to seek to influence another person's decision to further their own private interests, those of their relatives or friends or to improperly further those of another person. It reads as follows: 9. No public office holder shall use his or her position as a public office holder to seek to influence a decision of another person so as to further the public office holder's private interests or those of the public office holder's relatives or friends or to improperly further another person's private interests. In response to my letter, Ms. Fox submitted a written Attestation on July 2, 2025. The Office wrote again to Ms. Fox on July 5, 2025, asking that she provide documentation referred to in the Attestation, all of which was submitted on July 10, 2025. An interview was conducted with her on January 27, 2026. The Office also interviewed four witnesses who, at the time of the events under examination, were employed at IRCC: Marie‑Flore Baptiste, Chief Human Resources Officer and Assistant Deputy Minister, Corporate Services; Tracy Perry, Acting Director General, Access to Information and Privacy Management; Vera Azzi, Office Manager, Office of the ADM, Corporate Services; and Mr. Charles. The Office also obtained written information from one additional witness from IRCC, Nicole Primeau, then Director General of Audit and Investigation and Senior Officer for Internal Disclosure, and received documents from IRCC, including all documents gathered in the context of their investigation into the appointment of Mr. Charles.​ In keeping with the Office's practice, I provided Ms. Fox with a copy of the relevant documentary evidence gathered during this examination, as well as a draft copy of the factual portions of the examination report (Referral, Concerns and Process, Facts, Issues and Ms. Fox's Position). Before the report was finalized, Ms. Fox provided comments and additional submissions dated March 13, 2026. Facts Background The department of Immigration, Refugees and Citizenship Canada (IRCC) Ms. Fox was Deputy Minister of IRCC from July 2022 to January 2024. In her capacity as Deputy Minister, Ms. Fox oversaw 1 associate deputy minister, 10 assistant deputy ministers, and 13,685 employees. According to the Privy Council Office's Guidance for Deputy Ministers, deputy ministers are the “deputy head[s] of the Department" and have a role in human resources management within the public service. They lead the development of the public service by ensuring merit-based appointments, a representation of linguistic duality and diversity, and by adapting to current and future needs of the department. Issues with access to information within IRCC Ms. Fox wrote in her Attestation and testified during her interview that when she was appointed Deputy Minister of IRCC, the Clerk of the Privy Council and the Prime Minister gave her a clear mandate to lead cultural and organizational change. One area that required change was the processing and management of requests made under the Access to Information Act (ATIP requests). According to Ms. Fox, the workforce in the division responsible for ATIP requests lacked a focus on client service. She explained that the division was late for the majority of requests and ranked poorly in the Information Commissioner's reports. According to Ms. Fox, part of her duties was to address the challenges within the ATIP division based on her management team's reported concerns and the direct communications received from frustrated members of the public seeking information on their cases. Call to Action on Anti-Racism, Equity, and Inclusion Ms. Fox both testified and wrote in her Attestation that when she was appointed Deputy Minister of IRCC, the department was focused on anti-racism, diversity, and inclusion after grappling at multiple levels with issues of racism. She was mandated by the Clerk of the Privy Council to implement the Call to Action on Anti-Racism, Equity, and Inclusion in the Federal Public Service (Call to Action) and to address the challenges faced by Black employees in getting hired, as well as the barriers to recognizing the skills they have acquired both within and outside the federal public service. As a result, she supported diverse hiring practices and recommended candidates who could bring valuable experience and fresh perspectives, in line with these priorities. Ms. Fox's relationship with Mr. Charles In her written Attestation, Ms. Fox described Mr. Charles as an old acquaintance from the time she was at Carleton University, where they were both varsity athletes. She wrote that, while he is a few years younger, they share mutual connections through a large community of the university's former varsity athletes. Ms. Fox testified that she has rarely seen Mr. Charles since their younger years. She wrote that her spouse works at Carleton University as a basketball coach and knows Mr. Charles casually as part of the university's broader basketball community. Ms. Fox testified that Mr. Charles is one of the many athletes her spouse has encountered over his basketball career and that they maintain a relationship in the context of alumni events and as his former coach, but that they are not friends. Mr. Charles described his relationship with Ms. Fox as one of acquaintances. He confirmed that Ms. Fox's spouse was his assistant basketball coach while he attended university from 2001 to 2004. In the context of IRCC's investigation, Mr. Charles stated that he knew Ms. Fox's spouse very well and that as a member of the varsity team, he spent eight or nine months out of the year with him as his coach. When asked during his interview to describe his current relationship with Ms. Fox's spouse, Mr. Charles testified that he does not know him as well as he once did. Mr. Charles indicated that he, Ms. Fox and her spouse have friends in common, and that he sees them at a barbecue which takes place every couple of years and at yearly basketball alumni events. Mr. Charles recalled having once gifted Ms. Fox and her spouse a bottle of wine many years ago. Ms. Fox testified that she could not recall having received a bottle of wine or any other gift from Mr. Charles. According to Mr. Charles, he and Ms. Fox's spouse contact each other two to three times a year, usually by text message, and usually in the summertime when the university alumni events are approaching or after the basketball season has concluded. Mr. Charles stated that he might reach out to the basketball coach to congratulate him on a successful season or to enquire about his family. Mr. Charles said that they also speak when Mr. Charles attends basketball games or alumni events. Mr. Charles also testified that Ms. Fox's spouse is a third or fourth cousin of his father. During his interview, Mr. Charles said that he found out about the relationship about 10 to 15 years ago, but that was the extent of it. He did not know if Ms. Fox knew about his family ties to her spouse. In this regard, Ms. Fox wrote in her attestation that her spouse was of no relation to Mr. Charles and she testified that she was not aware of the family lineage. Given the remoteness of the relationship and the absence of any reference in the documentation to a possible family connection between Mr. Charles and Ms. Fox's spouse, I did not pursue this further. Mr. Charles' hiring at IRCC March 4, 2023: Mr. Charles speaks with Ms. Fox Mr. Charles testified that after having worked for several years as a GoodLife gym manager, he was ready for a change since it was becoming more challenging for him to meet the requirements for that job because of the birth of his child. He said he reached out to Ms. Fox at his spouse's suggestion. He testified that his spouse is not a friend of Ms. Fox. Mr. Charles testified that he did not know Ms. Fox's position within IRCC, only that she worked within the department. He could not recall how he came to know that she worked for this department. He said he was interested in working at IRCC since Ms. Fox worked there and thought she could pass along his résumé. Mr. Charles said that he could not recall whether he had applied for any government jobs prior to calling Ms. Fox. Mr. Charles said that he did not have Ms. Fox's contact information. As a result, he communicated with her spouse, who provided him with her cellphone number. When asked for details of the communication with Ms. Fox's spouse, Mr. Charles testified that he could not recall any details. Mr. Charles said he then reached out to Ms. Fox, who responded that there may be opportunities for him. They scheduled a date and time to speak. According to email evidence, Ms. Fox and Mr. Charles spoke on Saturday, March 4, 2023. Mr. Charles testified that during his call with Ms. Fox she asked him details about his job as a GoodLife gym manager, such as his responsibilities and tasks as well as his salary at that time. She also asked him what he was looking for in terms of employment and told him about opportunities within IRCC and possible fits for him. However, he could not recall whether they discussed the length of employment or a potential job category or level. According to Mr. Charles, Ms. Fox told him to send her his résumé and that someone at IRCC would be in touch. In her Attestation, Ms. Fox wrote that she received an unexpected and unsolicited call from Mr. Charles. She testified that she was not aware that her spouse had provided Mr. Charles with her number but noted that she is always open to speaking with individuals who are interested in joining the federal public service. Ms. Fox testified that Mr. Charles told her he wanted to make a career change for family reasons. She noted that he worked very long hours, including weekends, and that he was looking for employment with regular work hours. During their call, she recalled noting that Mr. Charles had good experience, including client service and managerial experience. Ms. Fox testified that she did not recall asking him about his salary, but did recall looking into his level of seniority in his organization. She invited Mr. Charles to send his résumé, which she would forward to the Assistant Deputy Minister (ADM) responsible for IRCC's human resources decisions and the department's ATIP division. Following their call, Mr. Charles emailed Ms. Fox his résumé, thanked her for their chat and wrote that he was “definitely excited for this opportunity." When asked which opportunity he was referring to, Mr. Charles testified that he was merely excited that Ms. Fox was willing to receive his résumé. March 6, 2023: Discussions with the ADM about changes within the ATIP division On March 6, 2023, Ms. Fox appointed Marie‑Flore Baptiste as her Chief Human Resources Officer and ADM, Corporate Services. According to Ms. Baptiste, she and Ms. Fox discussed issues within the department during bilateral meetings, specifically the ATIP division's inability to deliver on time and its high employee turnover. According to Ms. Fox, discussions on the difficulties with the ATIP division began with Ms. Baptiste's predecessor and continued after Ms. Baptiste's appointment, at which time she was mandated to make changes within the ATIP division in her role as ADM. Both Ms. Fox and Ms. Baptiste testified that the ATIP division required a major transition. They needed to change course by bringing in new technology and recruiting people from outside the federal government who would have a different mindset and change the culture, including in areas related to racism and discrimination. Ms. Baptiste said they also discussed looking for a business analyst to run a project for the ATIP division and that Ms. Fox had told her she knew people. Ms. Fox testified that she could not recall whether her discussions with Ms. Baptiste around needing people from outside the federal public service came before or after her telephone call with Mr. Charles. Ms. Fox further testified that she did not recall any discussions with Ms. Baptiste about a “business analyst" position. She did, however, recall Ms. Baptiste talking about transforming the ATIP division's client services into a system that would support a new way of working. March 15, 2023: Ms. Fox forwards Mr. Charles' résumé to the ADM In a March 15, 2023 email, Ms. Fox forwarded Mr. Charles' résumé to Ms. Baptiste, indicating that Mr. Charles was someone she knew from basketball, that he was not bilingual but had extensive experience in client services at GoodLife. She also indicated that he was very interested in immigration, noting that his parents are first-generation immigrants from the Caribbean. She asked Ms. Baptiste to let her know if Mr. Charles was a good fit. Ms. Fox testified that she sent Mr. Charles' résumé to Ms. Baptiste because she had asked for résumés of individuals from outside the federal public service, and because she was motivated by the Call to Action to bring on greater diversity into the department. She believed that if Mr. Charles, a diverse candidate who had client service and management experience, was interested in joining the federal public service, he could be an interesting fit for the ATIP division. Ms. Baptiste testified that it was during a discussion with Ms. Fox that Mr. Charles was identified as the candidate who could fill the position of project manager responsible for modernizing the ATIP division's client experience. Ms. Fox testified that she was constantly forwarding résumés of individuals that came her way. Other than Mr. Charles' résumé, neither Ms. Fox nor Ms. Baptiste could recall Ms. Fox sending any other résumés of external candidates for the ATIP division. Ms. Fox both wrote in her Attestation and testified that, as far as she was aware, after sending Mr. Charles' résumé, Ms. Baptiste and a hiring team took over from then on. March 21, 2023: Mr. Charles meets with the ADM On March 21, 2023, Ms. Baptiste met with Mr. Charles. Ms. Baptiste testified that she initially felt compelled to interview Mr. Charles herself because his résumé had come from Ms. Fox. She said that she wanted to make sure, before forwarding his résumé to departmental officials, that Mr. Charles had the necessary competencies and that he would fit into the new culture they were trying to establish. Mr. Charles testified that during their meeting, Ms. Baptiste asked about his work history, but that they did not discuss his salary, any specific job opportunities, or the possible duration of employment. Ms. Baptiste testified that they discussed his project management experience and opportunities within the ATIP division. According to Mr. Charles, Ms. Baptiste said she believed he had good client service and project management skills and that someone would contact him, but that it could take a while because “things" tended to move slowly. According to Ms. Baptiste, following her meeting with Mr. Charles, she informed Ms. Fox that she would not hire Mr. Charles without him having first met with departmental officials. In her Attestation, Ms. Fox wrote that following his call with the ADM, Mr. Charles emailed her to thank her for sharing his résumé. Both Ms. Fox and Mr. Charles testified that he told her that the meeting had gone well and that things were proceeding. According to Mr. Charles, Ms. Fox asked that she be kept informed. Ms. Fox testified that this request was simply out of courtesy. March 15, 2023: ATIP senior management are asked to meet with Mr. Charles On March 15, 2023, Ms. Baptiste forwarded Mr. Charles' résumé to Tracy Perry, Acting Director General, Access to information and Privacy Management, asking if they could discuss Mr. Charles as a potential resource for the ATIP division. Ms. Perry testified that she initially ignored Ms. Baptiste's email because Mr. Charles' résumé did not look relevant. However, documentary and testimonial evidence shows that by late March, she was having regular discussions with Ms. Baptiste about Mr. Charles. According to Ms. Perry, Ms. Baptiste told her that Mr. Charles' résumé came directly from Ms. Fox and that he would be a great addition to the team due to his outside government experience and perspective. Again according to Ms. Perry, she told Ms. Baptiste that since Mr. Charles had no French language skills and no experience in government, he could only be offered an entry-level position. However, Ms. Baptiste had said that an entry-level position would not suffice as Ms. Fox expected the department to recognize Mr. Charles' client service experience and be given a salary equivalent to what he was earning from the private sector, which would be from a PM‑04 position. Ms. Fox testified that she did not instruct nor exert any pressure on Ms. Baptiste to appoint Mr. Charles to any specific level or position that would match what he earned as a manager at GoodLife. According to Ms. Fox, it was Ms. Baptiste who thought Mr. Charles would be a good fit for a PM‑04 position within the ATIP division. In an instant message exchange on March 30, 2023, staff in Ms. Baptiste's office followed up with Ms. Perry asking if she would have the chance to touch base with Mr. Charles that day. Ms. Perry forwarded the message to François Jetté, Acting Director, ATIP Innovation and Support, stating that they had to meet with Mr. Charles, to which Mr. Jetté responded: “Holy geez, tell her to lay off with this guy already…" Ms. Perry testified that while she never spoke directly with Ms. Fox about Mr. Charles, she believed Ms. Baptiste was feeling pressure from Ms. Fox to have the department meet with Mr. Charles, which caused Ms. Baptiste to exert pressure on her and her staff. A meeting was scheduled for April 4, 2023 between Mr. Jetté and Mr. Charles. In an instant message on April 3, 2023, Mr. Jetté wrote to Ms. Perry that he was meeting with the “DM's best friend" the following day. While asking her to recapitulate what she thought Mr. Charles could do, he suggested potential tasks and responsibilities, such as returning to a client focus for the ATIP division and looking for process improvements. He also wrote that it was to be a one-year term at a PM‑04 level to start. Ms. Perry responded that Mr. Charles could also help another ATIP team review their interactions with clients to see if any changes could be made. Ms. Fox testified that she likely learned about this meeting in an exchange with Mr. Charles. She testified that she invited Mr. Charles to debrief her following his meeting with Mr. Jetté both as a courtesy and because she felt there was resistance to change within the department. She wanted to make sure the meeting had been a positive experience for him. She said that the integration of racialized individuals into the department, and ensuring their skills were recognized, was top of mind for her. However, she testified that she had not heard of any resistance relating to Mr. Charles from the department at that point. April 3, 2023: Ms. Fox sends an internal IRCC document to Mr. Charles to help him prepare for his interview before his meeting with IRCC officials In an April 3, 2023 email, Ms. Fox forwarded to Mr. Charles an internal IRCC briefing document, indicating that it might be useful in providing him with an overview of the department. She wrote that while no one would expect him to know the details, she thought it could be helpful in preparation for his meeting, and that they could chat afterward. Mr. Charles thanked her for the document indicating that he would review it before his meeting. When asked how Ms. Fox knew about his upcoming meeting with the departmental official, Mr. Charles testified that he did not know. Ms. Fox testified that she believes Mr. Charles had informed her about his upcoming meeting. Based on the title of the attachment, Min COS Briefing – Immigration and Citizenship Canada – Departmental Overview – Updated Feb 14, the briefing document was prepared for the new acting Chief of Staff of the Minister of IRCC. The document provided a snapshot of the department's mandate and core responsibilities, main programs and initiatives such as settlement programs, Canada's managed approach to immigration, temporary residents, etc. Both Ms. Perry and Ms. Baptiste testified that it was an internal document. Ms. Fox described it as a briefing document that is regularly updated and testified that she would have received a version of the same document when she was appointed Deputy Minister of IRCC. She said that she has shared the document with stakeholders, parliamentarians, ministers and ministers' offices. Ms. Fox said that the content could be found in various reports, such as annual reports and the public disclosure of briefing materials for a new minister. When asked whether any other candidate would have received the same document, Ms. Fox said that anyone preparing for an interview could call IRCC's human resources and request background information on the department. April 4, 2023: Mr. Charles meets with Mr. Jetté Shortly before his meeting with Mr. Charles, Mr. Jetté informed Ms. Baptiste in an instant message that he was meeting with “the person she'd been asked about several times." Ms. Baptiste replied stating that they needed someone with Mr. Charles' type of client service viewpoint and that Ms. Fox was “pushing this from outside thinking and client focus." In respect of his April 4, 2023 meeting with Mr. Jetté, Mr. Charles testified that they discussed a job opportunity and that he was asked how he would handle certain situations, workloads and high-stress environments. In an instant message exchange following the interview, Mr. Jetté informed Ms. Perry that he “quite liked" Mr. Charles. Ms. Perry responded that she needed to speak with IRCC's human resources about options. She testified that she sought advice because she was not comfortable offering Mr. Charles a term position. April 12, 2023: Information note to the Deputy Minister includes information on Mr. Charles' hiring as a PM‑04 In preparation for an April 12, 2023 trilateral meeting with Ms. Fox and her Associate Deputy Minister, Ms. Baptiste requested from Ms. Perry that information relating to the anticipated hiring of Mr. Charles be included in a note known as a “DM Weekly" for Ms. Fox's information. Ms. Baptiste testified that because Ms. Fox had sent Mr. Charles' résumé, and because it was the only résumé she had sent, Ms. Baptiste wanted to have the information to update Ms. Fox. Furthermore, Ms. Baptiste added that the hiring in the ATIP division was an overall priority for Ms. Fox and that she had asked for updates “a couple of times." Ms. Fox testified that she was not requesting updates on Mr. Charles, but rather she was seeking updates on the transformation of the ATIP division as its performance indicators were a standing item on her bilateral meetings with Ms. Baptiste, who she said regularly solicited and welcomed managerial support on routine matters. She said that the pressure was about improving the ATIP division. As a result, staff included in the DM Weekly note information relating to interviews that had been held for two positions in the ATIP division: a PM‑06, who would lead the software replacement project, and a PM‑04. For the PM‑04 position, staff added the following information: The prospective PM‑04 will provide advice and ens​​​ure a client focus is provided to the project and all ATIP client interactions moving forward. The potential candidate has over 12 years experience in the client service industry and will bring a unique perspective to how we are currently delivering our services to ATIP clients. Conversations are ongoing with HR to identify the quickest path to bringing the two individuals on board. While reviewing the DM Weekly note before sending it to the Deputy Minister's office, Vera Azzi, Office Manager, Office of the ADM, Corporate Services, instant messaged Ms. Perry asking her why the hiring of a PM‑04 was included in the note and questioned the relevance of including such information in a briefing for a Deputy Minister. Ms. Perry replied that the Deputy Minister would want this information given that she had referred Mr. Charles to the department. Ms. Perry added that staff could not specify in the note that Mr. Charles was a referral from Ms. Fox so as to avoid a paper trail. When asked about the exchange between Ms. Azzi and Ms. Perry, Ms. Fox testified that the department's hiring was a very minor part of her day-to-day responsibilities. She said she did not convey any pressure to Ms. Baptiste and was upset to read Ms. Perry's message as she does not believe it reflected her motivation or her actions. During the April 12, 2023 trilateral meeting, Ms. Baptiste recalled that very little was discussed about Mr. Charles. Following the trilateral meeting, on April 13, 2023, Ms. Azzi sent an email to Ms. Perry, informing her that the DM Weekly had been shared with the Deputy Minister and included a screen shot of the note with Ms. Fox's handwritten comments: “PM‑04 would be great. Allows him to integrate." There was no written comment from the Deputy Minister about the PM‑06 position. Ms. Perry testified that she understood Ms. Fox's handwritten comment about Mr. Charles to be another indicator that the department needed to continue with his hiring. Ms. Fox confirmed that it was her handwriting. She testified that her comment reflected on her satisfaction that Mr. Charles, a racialized individual, would have his external experience recognized within the government system, which had been an identified gap in the reporting Ms. Fox had received from the Anti-Racism Secretariat. She said that her statement that a PM‑04 level would allow Mr. Charles to integrate was not about the salary level, but rather about allowing him to use and apply his management and client service skills at an appropriate level within the federal system. She further testified that for racialized individuals, the department tended to offer the lowest level possible. In the same April 13 email to Ms. Perry, Ms. Azzi also wrote, “... for the recommended candidate from Good[L]ife, the DM and ADM want to know how long it will take to bring this person in?" Ms. Azzi did not receive a response to her question. Documentary evidence shows that following her email, Ms. Azzi followed up with departmental staff on three additional occasions in the three weeks that followed her initial email, regarding the hiring of Mr. Charles. Ms. Azzi testified that if she was following up with the department, it was because Ms. Baptiste had been asked by Ms. Fox for an update, Ms. Fox's staff had enquired with staff in the ADM's office, or Ms. Baptiste had an upcoming meeting with the Deputy Minister where she would be asked to provide an update. Ms. Azzi testified that it was uncommon for her, in her role as the ADM's Office Manager, to be seeking updates on the hiring of a PM‑04 position. She further testified that, in her experience working in an ADM's office, it was uncommon for a Deputy Minister to enquire about a specific résumé, especially for a candidate considered for a low-level position such as a PM‑04. Ms. Baptiste confirmed that it was indeed uncommon for a Deputy Minister to enquire about a specific candidate being considered for a low-level position. Ms. Fox testified that she did not recall ever asking for timing around Mr. Charles' hiring. She also testified that it was not uncommon for her to enquire about a specific candidate at a low-level position. She said that while she was not involved in the day-to-day management and hiring of the department, she would be involved depending on the context. Ms. Fox further testified that she would describe her discussions with Ms. Baptiste about Mr. Charles as a very minor topic among the countless day-to-day tasks she had as Deputy Minister of IRCC. Departmental staff have concerns Documentary evidence in the form of emails between departmental senior staff shows there were concerns with Mr. Charles receiving a PM‑04 position. Because of his lack of government and ATIP experience, he did not meet the qualifications in the statement of merit criteria to be appointed to a PM‑04 term position. As a result, departmental staff recommended to Ms. Baptiste that they proceed with a casual appointment. Ms. Perry testified that her concerns were that a PM‑04 level within the ATIP division is a supervisory position which requires an individual to be bilingual, have knowledge of laws relating to access to information and privacy, and have knowledge and experience using the related software to manage a team. She said Mr. Charles was being brought in without any of the required experience and knowledge when there was existing staff with years of experience who were deserving of the level, but who had not had an opportunity to participate in a process to compete for the level. Ms. Baptiste testified that since Mr. Charles was coming from the private sector, she did not expect that he would know legislation relating to ATIP or government policies and practices. As a result, she did not expect that he would meet the merit criteria. Ms. Perry confirmed that the department had recently updated their job descriptions and were now using a generic job description for ATIP positions, which posed a challenge when they were asked to create a unique position specifically for Mr. Charles. Ms. Fox testified that she was unaware about the department's position that Mr. Charles did not meet the qualifications in the statement of merit criteria for the PM‑04 position. April 24, 2023: Ms. Fox weighs in on Mr. Charles' proposed position level Mr. Charles testified that during a follow-up meeting, Mr. Jetté told him that he was considering offering him a PM‑02 position and that he had to consider available positions within his team and whether Mr. Charles would be a “good fit." The documents provided by IRCC show that Mr. Charles told IRCC investigators that he felt uneasy with a PM‑02 position as he was concerned with the level of pay. Mr. Charles testified that, following this meeting, he informed Ms. Fox about Mr. Jetté's intent to start him at the PM‑02 level. According to Mr. Charles, Ms. Fox stated that she hoped the department would value his experience in dealing with clients. Ms. Fox testified being surprised by the news given her previous discussions with Ms. Baptiste about a PM‑04-level position. In an April 24, 2023 email to Ms. Baptiste with the subject line “follow-up," Ms. Fox wrote: I wanted to touch base on BJ Charles – he has met with your team and is very excited. I had understood the PM4 was an option for him which I think makes sense. I think he is being offered a PM2 which may make it tough to leave current position…. any flex on this to recognize his experience outside the federal system? Sorry to bug you on this in the middle of the strike! Ms. Baptiste replied to Ms. Fox confirming that they were proceeding with a PM‑04-level position and that she had been informed by staff that they had told Mr. Charles that outside recruits were usually offered a PM‑02 position. Ms. Baptiste further wrote that given Mr. Charles' experience, she would make sure they would proceed with a PM‑04 level. When asked what she meant when she wrote that a PM‑02-level position might make it difficult for Mr. Charles to leave his current employment, Ms. Fox testified that while for him it might have been difficult due to the lower salary, for her it was about ensuring Mr. Charles was not automatically appointed to an entry-level position, as is the case with many racialized individuals entering the federal public service whose experience and skills are not recognized due to racism. When asked about the email subject line, Ms. Fox testified that “follow-up" was a common way for her to initiate her emails. Ms. Fox testified that Ms. Baptiste told her that she was receiving pushback from the department because it was resistant to change. Ms. Fox said that it was her view that the department tended not to recognize external skills and had gaps in how it recognized diverse candidates in terms of talent mapping. Ms. Fox wrote in her Attestation that she used the situation to provide support and mentoring to Ms. Baptiste as a newly promoted ADM. She encouraged Ms. Baptiste to use her judgment with respect to Mr. Charles and not rely without question on the advice from her management team and to challenge hiring practices that had been brought to her attention as obstructing progress on the Call to Action. Ms. Fox testified that as a new ADM, Ms. Baptiste struggled with some of the human resources decisions. She said that she supported Ms. Baptiste and that their bilateral meetings often centred on helping Ms. Baptiste make decisions relating to human resources that were required of her as an ADM, such as removing barriers for employees and recruiting racialized individuals. However, she testified not knowing that the department had determined that Mr. Charles did not have the qualifications to meet the statement of merit criteria for a PM‑04 position within the ATIP division. Ms. Fox wrote in her Attestation that she relied on Ms. Baptiste and the hiring team to make human resource decisions and did not seek to become involved. According to Ms. Fox, she had no further involvement in Mr. Charles' hiring process and did not recall any further discussions with Ms. Baptiste about the matter. Ms. Baptiste testified that when she received Ms. Fox's April 24 email, she was not aware that staff had proposed offering Mr. Charles a lower position. She said that she did not feel that she had any choice but to appoint Mr. Charles to a PM‑04 position because not doing so would mean having to depart from her initial conversation with Ms. Fox relating to Mr. Charles. Ms. Baptiste further added that she felt uncomfortable offering Mr. Charles a lower position because Ms. Fox had told her during a bilateral meeting that Mr. Charles had recently had a baby. Ms. Fox testified that she did not recall Mr. Charles bringing up a baby with her and did not think she would have brought that up with Ms. Baptiste. According to Ms. Azzi, Ms. Baptiste appeared stressed about the PM‑04 hiring and that since this was a request of importance to Ms. Fox, she believed Ms. Baptiste felt it needed to get done. Ms. Azzi also testified that, in her view, Ms. Baptiste felt obligated to hire Mr. Charles because she herself had been hired by Ms. Fox. Documentary evidence shows that departmental staff felt pressured to quickly bring Mr. Charles into the department all the while respecting human resources rules. In an April 24, 2023 instant message to Ms. Baptiste, Ms. Perry wrote: “Please let the DM know we are working as hard as possible, especially with the limited staff we have right now, to make this a reality as quickly as possible." Ms. Baptiste testified that there was indeed an urgency to fill the position because Ms. Fox wanted Mr. Charles hired and because of the pressure to improve the ATIP division's performance. April 27, 2023: Mr. Charles is offered a casual PM‑04 position On April 27, 2023, Mr. Charles was offered a three‑month casual PM‑04 position, which he accepted. Documentary evidence shows that departmental staff expedited Mr. Charles' letter of offer, security clearance, ID card and access to the necessary office equipment for his first day of work. June 2023: Departmental staff work on a term position for Mr. Charles On May 11, 2023, Mr. Charles began working as a Client Experience Advisor on the Innovation and Support team within the ATIP division, which was responsible for the software replacement project, the migration to an ATIP online portal, related training, etc. In an instant message exchange, Ms. Baptiste and Ms. Perry discussed the plan to move Mr. Charles to a term position as soon as possible. In an instant message on June 22, 2023, Ms. Perry stated to Mr. Jetté that Ms. Baptiste had asked her whether they had begun the paperwork to give Mr. Charles a two‑year term at the PM‑04 level. She wrote that this was at the request of Ms. Fox. When asked about her instant message to Mr. Jetté, Ms. Perry testified that she could not recall Ms. Fox weighing in on Mr. Charles' term length. However, she surmised that if she relayed this message to Mr. Jetté, she must have been informed by Ms. Baptiste. Ms. Baptiste stated that she could not recall any discussion with Ms. Fox regarding a desired length of term for Mr. Charles but did recall that after he was appointed to the casual PM‑04 position, Ms. Fox continued to occasionally enquire about him. Ms. Fox testified that she does not recall enquiring about Mr. Charles after he was hired. She stated that she was not aware that Mr. Charles had been offered a casual position, and that she never had any discussions with Ms. Baptiste about his term length. In an email on July 25, 2023, a staff member in human resources updated their supervisor, informing them that a position was created specifically for Mr. Charles and that a term position would be offered to him. September 2023: Mr. Charles is offered a one-year term as a PM‑04 Instant messages between senior staff in the ATIP division as well as evidence gathered in the course of IRCC's investigation interviews show that Mr. Charles struggled with the tasks given to him. Ms. Perry testified that she was told that Mr. Charles was struggling to understand the subject matter and was underperforming in what was being asked of him. As a result, Mr. Charles was transferred to a different team within ATIP, which had more of a focus on client services, and was given new tasks. However, evidence shows he continued to struggle to perform. Mr. Charles testified that it was “news to [him]" and said that no one spoke to him about him having any performance issues. Despite his performance issues, on August 14, 2023, Mr. Charles was offered and accepted an external, non-advertised one-year term at the PM‑04 level beginning on September 20, 2023. According to documentary evidence, the statement of merit criteria was modified, allowing Mr. Charles to meet the requirements despite his minimal experience. Ms. Perry testified that she did not feel the department had any other choice but to offer Mr. Charles a term appointment at the PM‑04 level. Ms. Baptiste testified that she believed Mr. Charles should be given the chance to prove himself before being offered a lower position. According to the articulation of the selection decision documents, departmental staff in human resources consulted the employment equity document and noted that there were indeed gaps within the organization. However, staff also noted that Mr. Charles did not belong to an employment equity group. Mr. Charles testified that he was not aware that he did not self-declare being part of an employment equity group and did not recall whether he was ever asked. Mr. Charles further testified not recalling Ms. Fox ever discussing with him the public service's Call to Action. Ms. Azzi testified that she recalled the Call to Action being discussed at large within IRCC at the time, however, she could not recall any discussions regarding the Call to Action in relation to Mr. Charles' appointment. Ms. Perry testified that the Call to Action was not mentioned to her regarding Mr. Charles, however, she acknowledged that someone should have asked him whether he had wanted to self-declare. Ms. Fox testified that when she forwarded Mr. Charles' résumé to Ms. Baptiste, they discussed how his referral and hiring related to the gap they had identified in ATIP client services and to the objectives of the Call to Action by bringing diversity to the workforce. Evidence shows that staff in the ATIP division were surprised by the sudden arrival of Mr. Charles. Given that he was hired as a casual employee and then appointed to a term position for which no departmental staff considered him to be qualified, many assumed he had been personally brought in by someone who knew him. Evidence also shows that senior staff referred to him as “the DM's friend." Ms. Perry testified that the hiring of Mr. Charles caused a multitude of challenges within the ATIP division. She said that morale was greatly affected when staff found out that an individual with no French language skills and without any government experience or knowledge had been brought in and appointed to a PM‑04 position. Ms. Perry further testified that, had there not been what she described as a dedicated campaign of pressure from Ms. Fox and her office, the department would not have offered a casual or a term PM‑04 position to Mr. Charles. IRCC investigates Mr. Charles' appointment at the PM‑04 level In August 2023, IRCC began conducting an internal investigation into wrongdoing in respect of several staffing actions. The investigation at that time did not include the hiring of Mr. Charles. In a written submission to this Office, Nicole Primeau, then Director General of Audit and Investigation and Senior Officer for Internal Disclosure, stated that in the course of a bilateral meeting with Ms. Fox in the early fall of 2023, she provided the Deputy Minister with a high-level summary of a disclosure and recent evidence relating to the hiring practices within the ATIP division and recommended that the investigation be expanded. According to Ms. Primeau, Ms. Fox told her that she was aware of the hiring of one individual, Mr. Charles specifically. Ms. Fox informed her that she had referred Mr. Charles to the ADM as a possible candidate. Ms. Primeau wrote that Ms. Fox told her there was no reason to expand the investigation to include the ADM because she had simply shared the résumé with the ADM and that she had not directed the ADM to hire Mr. Charles. Ms. Fox told her it was likely a misunderstanding and that she was going to speak to Ms. Baptiste to clarify that when she shares résumés with ADMs, there is no expectation that the individual be hired. According to Ms. Primeau, she told Ms. Fox that Mr. Charles was hired into a position for which he was not qualified given his background as a manager of a GoodLife gym. Ms. Fox disagreed, telling Ms. Primeau that his experience was transferable to the public sector and that he was hired because of his customer service experience to lead a special project within the division. Ms. Fox testified that she did not attempt to exclude Mr. Charles' appointment from the investigation. She said that during their discussion, Ms. Primeau mentioned that the investigation centred on individuals in the ATIP division hiring family members and that Ms. Baptiste may have been involved because it was assumed she had hired a relative, Mr. Charles. Ms. Fox said that she sought to clarify with Ms. Primeau that Mr. Charles was not a relative and that it was she who had referred him to Ms. Baptiste. She said that she told Ms. Primeau that while she had shared his résumé, it was always under the premise that people could make their own decisions. Documentary evidence provided by IRCC shows that the department's investigation into wrongdoing was nonetheless expanded to include the appointment of Mr. Charles at thePM‑04 level. On this matter, IRCC's report, completed in January 2025, found that he had no experience related to the proposed position and that human resources had concerns about him not meeting the merit criteria. The report found that he was granted the PM‑04 casual and term positions because of his relationship with Ms. Fox, which amounted to preferential treatment. The report further noted that a PM‑04 position is not an “entry-level" position within IRCC's ATIP division. As a result, the preferential treatment granted—both in obtaining employment and obtaining a relatively high level within the team—was considered significant. June 2024: Mr. Charles seeks another job Documentary and testimonial evidence shows that Mr. Charles was told that due to his ongoing performance issues, his term would not be renewed at the PM‑04 level. Ms. Baptiste testified that she was informed by Ms. Perry that Mr. Charles was not meeting expectations at the PM‑04 level. Mr. Charles testified that he was informed in the summer of 2024 that his term would not be renewed because the position would no longer exist. He said he contacted Ms. Fox, aware that she was now Deputy Clerk of the Privy Council and Associate Secretary to the Cabinet, to enquire about job opportunities at the Privy Council Office (PCO). Mr. Charles could not recall the way in which he contacted Ms. Fox. He testified that he believes they would have spoken about IRCC's investigation into his appointment to a PM‑04 position, which was ongoing at the time. In her Attestation, Ms. Fox wrote that, in or around June 2024, Mr. Charles contacted her and told her that he wished to leave IRCC. She testified that he told her that his experience at IRCC had not been positive, that there were poor management practices within the ATIP division, and that he did not feel he was given a fair opportunity. She expressed to Mr. Charles that she was not aware whether there were any openings at the PCO but nonetheless told him to send his résumé to her assistant. She informed the ADM responsible for Human Resources at the PCO that Mr. Charles would be sharing his résumé. According to email evidence, Ms. Fox's assistant scheduled a meeting between Mr. Charles and the ADM for June 12, 2024. When asked what she told the ADM about Mr. Charles, Ms. Fox testified that she told the ADM that that his experience at the department had been terrible from a professional standpoint. She also told the ADM that she was unaware whether the PCO's ATIP division had similar needs as IRCC did, but that if he was looking for staff, Mr. Charles was looking for a new opportunity. According to Ms. Fox, the ADM told her that they were always looking to hire, whether it was in the ATIP division or another division, and he told her to send him Mr. Charles' résumé and that they would be happy to meet with him. Ms. Fox testified that she did not tell the ADM that she had referred Mr. Charles to Ms. Baptiste or that Mr. Charles was an acquaintance of hers from the varsity basketball community. On June 12, prior to his meeting with the ADM, Mr. Charles first met Ms. Fox at her office. According to Mr. Charles, Ms. Fox told him about the employment opportunities at the PCO. She then walked him down to the office of the ADM and provided introductions to the ADM and a senior director with the ATIP division, who was also present. He said they chatted until Ms. Fox left for another meeting. Mr. Charles said that following his meeting with the ADM, he then met with the senior director in charge of the ATIP division. According to Ms. Fox, following their meeting with Mr. Charles, the ADM informed her during a bilateral meeting that their discussion had gone well. According to Mr. Charles, in early September 2024, he received a verbal offer of employment for a PM‑04 ATIP Analyst position from the PCO. Mr. Charles testified that he told Ms. Fox about the job offer with the PCO. On September 13, 2024, Mr. Charles accepted a two-month term extension at the PM‑04 level with IRCC. On October 22, 2024, he accepted a demotion to a CR-04 position with IRCC, which was to start once his PM‑04 term extension came to an end. According to Mr. Charles, the acceptance of the CR-04 position was a means of staying employed while waiting to receive the Top Secret clearance he required to work at the PCO, a process he was told could take up to six months to complete. Mr. Charles testified that he informed PCO officials of the upcoming demotion. On October 25, 2024, Mr. Charles signed his written letter of offer for a PM‑04 ATIP Analyst position at the PCO. He then received his Top Secret clearance within two months, allowing him to start his new job at the PCO on November 7, 2024, before the end of his PM‑04 term extension and planned demotion to CR‑04 at IRCC. Issues The issues to be addressed are as follows: Did Ms. Fox use her position as Deputy Minister of IRCC to seek to influence departmental officials into hiring an alleged friend, Mr. Charles?In the absence of any finding of such friendship, did Ms. Fox use her position as Deputy Minister to seek to influence departmental officials to hire Mr. Charles in a manner that would have improperly furthered his private interests? Ms. Fox's position In her written Attestation of July 2, 2025, Ms. Fox denied the allegation made against her and stated that Mr. Charles is not a friend and that she did not exert undue influence or pressure on public servants to hire Mr. Charles or otherwise seek to improperly further his private interests in contravention of section 9 of the Conflict of Interest Act (Act). Ms. Fox testified that as a senior public servant, she has a deep respect for, and an understanding of, her obligations under the Act. She submitted that she consistently discharged her duty as a public office holder appropriately and with a view to furthering the Government of Canada's interests. Ms. Fox submitted that as Deputy Minister of Immigration, Refugees and Citizenship Canada (IRCC), she was given a clear mandate by the then-Clerk of the Privy Council to lead cultural and organizational change at IRCC, which had a reputation as an organization resistant to change and with poor performance in serving clients and ministers. It was a large-scale organizational challenge which she approached with an acute understanding of her responsibility to lead by example. One area of concern was within the Access to Information and Privacy (ATIP) division. It suffered from a high turnover and chronic lack of ATIP officers, which resulted in challenges in complying with the timelines set out in the Access to Information Act. According to Ms. Fox, at the time of her appointment, IRCC was also grappling with issues of anti-racism, diversity and inclusion. She wrote that the Clerk of the Privy Council had specifically mandated her to implement the Call to Action on Anti-Racism, Equity, and Inclusion in the Federal Public Service. She was cognizant of the findings of the Anti-Racism Secretariat that Black employees at IRCC faced challenges in getting hired and barriers to having their skills gained within and from outside the federal public service. Ms. Fox stated that it is accurate that she brought Mr. Charles' interest in a position at IRCC to the attention of her Assistant Deputy Minister (ADM). She added that the allegations that Mr. Charles is her friend or that she exerted pressure on public servants to hire him are false. She submitted that her relationship with Mr. Charles meets none of the indicators of friendship for the purposes of the Act, as expressed in various publications and reports issued by this Office. She also submitted that friendship under the Act has been interpreted as requiring a close bond, feeling of affection or special kinship. Sharing an alma mater is insufficient to meet this standard. According to Ms. Fox, Mr. Charles' hiring was routine and took very little of her time. She was involved in a limited way and to an entirely appropriate degree in Mr. Charles being considered for a position at IRCC: first by directing his résumé to her newly appointed ADM and then, indirectly, by encouraging her new ADM to confidently state her view on Mr. Charles' potential rank to the hiring team. According to Ms. Fox, her attempts to support Ms. Baptiste in her role as ADM should not be mistaken for pressure and that Ms. Baptiste never conveyed to her that she was feeling pressured. Rather, Ms. Baptiste seemed appreciative of the mentoring and support provided to her. Ms. Fox believes Ms. Baptiste may have lacked confidence in her authority as an ADM and as a result may have invoked her name to manage difficult staff within the ATIP division. Ms. Fox submitted that her actions in relation to Mr. Charles' hiring were proper, that no additional or improper actions were taken and that she complied with her professional obligations as a Deputy Minister. Ms. Fox added that she took the actions she did because she thought Mr. Charles was a candidate who merited consideration in a time of dire need for acute talent within the ATIP division and in an effort to further the goals of the Call to Action and Corporate Priorities for deputy ministers, and for no other reason. Analysis and conclusion In this examination, I must determine whether Christiane Fox contravened section 9 of the Conflict of Interest Act (Act) by using her position as Deputy Minister of Immigration, Refugees and Citizenship Canada (IRCC) to seek to influence departmental officials into hiring an alleged friend, Björn Charles, or in the absence of any such friendship, whether Ms. Fox used her position as Deputy Minister to seek to influence departmental officials to hire Mr. Charles in a manner that would have improperly furthered his private interests. Section 9 of the Act prohibits public office holders from using their position to seek to influence another person's decision to further their own private interests, those of their relatives or friends or to improperly further those of another person. It reads as follows: 9. No public office holder shall use his or her position as a ​​​public office holder to seek to influence a decision of another person so as to further the public office holder's private interests or those of the public office holder's relatives or friends or to improperly further another person's private interests. The furthering of private interests One of the questions I must consider in relation to how section 9 of the Act applies to this matter is whether the private interests of Mr. Charles were furthered. It is an undisputed fact that, after being referred by the Deputy Minister, Mr. Charles was hired by IRCC on a casual basis in May 2023 for a three-month period as a project manager (PM‑04) and was subsequently offered, in August 2023, an external non-advertised one-year term contract at that same level, which he accepted. An employment contract with IRCC, whether on a casual or a term basis, is a private interest within the meaning of the Act notably because of the remuneration and benefits attached to the position.[i] The relationship between Ms. Fox and Mr. Charles The next matter to be addressed is whether, Ms. Fox and Mr. Charles are friends within the meaning of the Act. The Act does not define “friends" for the purposes of the Act. However, there are several reports by my predecessors where they have interpreted the term to mean individuals “who have a close bond of friendship, a feeling of affection or a special kinship."[ii] In October 2021, the Office published an information notice which sets out a number of indicators to assist public office holders in determining whether an individual is a friend.[iii] These include, among others, the duration of the relationship, the type and frequency of interactions, the sharing of meals, the giving of gifts, and displays of trust or affection. In respect of the application of these indicators, Ms. Fox's position is that her relationship with Mr. Charles does not qualify as a friendship for the purposes of the Act. I agree with Ms. Fox's position. The evidence gathered in this examination shows that Ms. Fox and Mr. Charles knew each other from both being involved in university basketball. While both described each other as old acquaintances, it appeared to me that the two of them are in fact connected through Ms. Fox's spouse, who was Mr. Charles' former assistant basketball coach. Mr. Charles described Ms. Fox's spouse as someone he had gotten to know very well in past years but more casually in recent years. Mr. Charles testified that he has kept in regular touch with Ms. Fox's spouse over time, mostly by text messaging when alumni events are approaching or at the end of the basketball season to congratulate him on the season. Both Ms. Fox and Mr. Charles testified that they neither socialize at each other's homes nor do they share meals or exchange gifts. Mr. Charles recalled giving a bottle of wine to Ms. Fox's family on one occasion. The extent of their personal interactions was described as being limited to attending events connected to their alumni status. The documentary evidence gathered also shows that Ms. Fox, in correspondence with her Assistant Deputy Miniter (ADM), described Mr. Charles as “someone she knew from basketball." While the documents show that Ms. Fox and Mr. Charles communicated in a friendly and informal manner, for example by using first names, the evidence shows that when Mr. Charles first reached out to Ms. Fox, he did so by obtaining her contact information from Ms. Fox's spouse. While Ms. Fox and Mr. Charles have known each other for more than two decades, their relationship does not appear to have changed over the years in that any gatherings or social interactions have been through larger social circles connected to their ties to university basketball. I am therefore of the view that the nature of the relationship falls short of a friendship within the meaning of the Act. Ms. Fox's use of her position to further the private interests of Mr. Charles Was there an impropriety? Since they are not friends within the meaning of the Act, I must next determine whether Ms. Fox used her position as Deputy Minister to seek to influence departmental staff to hire Mr. Charles and if so, whether it amounted to an impropriety. Using one's position to seek to influence, as the phrase is used in section 9 of the Act, should be understood in its ordinary meaning, which aligns with the definition of “influence" in Black's Law Dictionary (10th edition) as the “use of pressure, authority, or power, usu. indirectly, to induce action or change the decisions or acts of another."[iv] In several past examination reports, the Office has interpreted the word “improper" to apply to conduct that could be considered contrary to a rule, a regulation, or a process, or that would constitute a form of preferential treatment.[v] Ms. Fox's position is that she acted properly at all times, noting that the hiring decision belonged to her ADM and departmental staff. She stated that any intervention on her part was minor and related to her priorities to solve the challenges in the Access to Information and Privacy (ATIP) division and to further the objectives of the Call to Action on Anti-Racism, Equity, and Inclusion in the Federal Public Service, as well as supporting her newly appointed ADM. In The Finley Report (2015), then-Commissioner Dawson considered whether a proponent's private interest had been improperly furthered when the Minister gave their proposal preferential treatment. The Minister had singled out the proposal for external evaluation and, ultimately, for funding, despite it not meeting the established funding criteria and not having been recommended by the department. The report concluded that the giving of preferential treatment could, in and of itself, be sufficient to find an impropriety. In her testimony, Ms. Fox stated that she often passes on the résumés of individuals that come her way. This illustrates what would be standard treatment of requests from people she might know from outside or within the public service and who approach her to discuss their interest in seeking new opportunities. In such cases, a Deputy Minister would not typically get involved any further, especially where the said opportunities are far removed from their level of seniority. The evidence establishes that in the case of Mr. Charles, Ms. Fox was approached in her private sphere, as her spouse provided him with her contact information and she took his call over the weekend. Then, throughout the process that resulted in Mr. Charles' hiring, she had several follow-up communications directly with him about how the process was going and asked that she be kept informed. She also provided him with an internal briefing document destined for a high-ranking official to help him prepare for his interview. While the content of this document was largely publicly available, the document was nonetheless internal to IRCC. In her capacity as Deputy Minister, she and her office sought updates about him specifically, as stated by several witnesses and as corroborated by the documentary evidence. She also intervened on his behalf with her ADM when she learned directly from him that the department was going to offer him a lower position. There is also evidence that Ms. Fox mentioned to her ADM at a bilateral meeting that Mr. Charles had just had a baby, a fact that Mr. Charles testified had motivated his desire for a career change and that Ms. Baptiste testified made her feel uncomfortable about offering Mr. Charles a lower position. While Ms. Fox did not think she would have done so, I accept Ms. Baptiste's version of the event. This intervention was, in my view, an attempt to influence Ms. Baptiste's decision on Mr. Charles' level and salary. Then, shortly after he accepted a casual appointment, the documentary evidence and testimony of several witnesses show that she made enquiries with departmental staff about his status, though Ms. Fox stated that she did not recall doing so. In sum, rather than simply passing on Mr. Charles' résumé, Ms. Fox continued to communicate privately with him in respect of a process she was able to influence and followed up several times in her capacity as Deputy Minister with the person whose decisions would be determinative of Mr. Charles' employment. I consider that Ms. Fox's level of involvement and continued interest in respect of Mr. Charles' employment opportunities at IRCC were directed at influencing her newly appointed ADM to hire Mr. Charles, and to do so at a higher classification than the evidence suggests he would have otherwise received. Her conduct resulted in the giving of preferential treatment to Mr. Charles, which in my view amounts to an impropriety. I must now address Ms. Fox's position that her involvement was proper because it related, on the one hand, to her priorities to solve the challenges in the ATIP division, and on the other hand, to furthering the objectives of the Call to Action. Were Ms. Fox's interventions proper because Mr. Charles' hiring was meant to fill the needs of the ATIP division? According to the evidence, the ATIP division at IRCC suffered from a chronic lack of ATIP officers, which resulted in delays in processing and managing ATIP requests. The division was missing deadlines in a majority of cases and had to deal with communications from frustrated members of the public seeking updates on their requests. Evidence shows that Ms. Fox referred only one candidate to address the needs of the ATIP division, Mr. Charles, and he was the only candidate considered for this external non-advertised position related to client services. The evidence also shows that senior staff within the ATIP division were at a loss to determine what tasks Mr. Charles, who had no previous government or ATIP experience, would be given, all the while being pressured to quickly interview and hire him in early April 2023. Information about Mr. Charles' hiring was included in a “DM Weekly" briefing note, along with an update about another position in the ATIP division, at the PM‑06 level. Ms. Fox's only handwritten comment on the note related to Mr. Charles' interests, namely that the PM‑04 would be great for him. Following this briefing, the documentary evidence shows that Ms. Fox and Ms. Baptiste wanted to know from departmental staff how long it would take to bring Mr. Charles in. According to Ms. Perry, the department's job descriptions for ATIP positions posed a challenge when they were asked to create a unique position specifically for Mr. Charles, notably due to his lack of ATIP experience. Then when Mr. Charles informed Ms. Fox that the department was considering him for a lower PM‑02 position, Ms. Fox wrote to her ADM, once again, specifically about Mr. Charles and his interests, to see if there was “any flex" in considering him for the PM‑04 position, as the lower level would make it difficult for him to leave his current position. In addition to the departmental hiring team not having clarity on what tasks Mr. Charles was to perform when interviewing him, shortly after he started, Mr. Charles was transferred to another team in the ATIP division. This also leads me to believe that Mr. Charles' hiring was not part of a coordinated plan to address the priority needs of the ATIP division. Overall, in weighing the evidence gathered, I conclude that Mr. Charles' hiring could not reasonably be foreseen to respond appropriately to a general need to hire qualified staff to address the specific and pressing challenges faced by IRCC's ATIP division. Rather, in my view, the task at hand was to create a position to fit the profile and desired salary range of a specific individual referred by the Deputy Minister. Consequently, I do not accept Ms. Fox's position that her interventions were proper because general ATIP priorities motivated her involvement as Deputy Minister in Mr. Charles' hiring. Were Ms. Fox's interventions proper because they were motivated by objectives of the Call to Action? On this point, I saw no mention of the Call to Action in any of the documentation prepared by departmental staff relating to Mr. Charles' hiring. The ADM's Office Manager testified that while the Call to Action was discussed at IRCC at large in 2023, she did not recall any mention of the Call to Action or other diversity, equity, and inclusion considerations in respect of the hiring of Mr. Charles. According to the evidence, neither Mr. Charles nor the department identified Mr. Charles as belonging to an employment equity group in the decision for his term appointment. Mr. Charles also testified that he could not recall whether he was ever asked about self-declaring as being part of an employment equity group. While the Call to Action is a specific and meaningful objective and requires actions from those responsible for leadership, in this specific case, I am unable to conclude that the Call to Action motivated Mr. Charles' hiring or Ms. Fox's conduct in the matter. Conclusion I consider the sustained interest and involvement by the Deputy Minister in relation to the hiring of Mr. Charles, whom I have determined was not a friend within the meaning of the Act, to constitute preferential treatment amounting to an impropriety. The evidence shows that Ms. Fox used the weight of her position as Deputy Minister to advance Mr. Charles's private interests by: (1) sending his résumé to her ADM with the expectation that departmental officials would quickly meet with him, (2) seeking updates from him and departmental officials about his hiring, (3) providing him with an internal document, and (4) pushing for a higher classification. I did not find her justifications relating to her interventions being motivated by the needs of the ATIP division and the Call to Action credible. Clearly, the true intent behind her interventions was to help Mr. Charles find new employment, and this occurred under her watch through the creation of a position in her department to fit Mr. Charles' needs. Given the above, I find that Ms. Fox contravened section 9 of the Act by using her public office to improperly influence her ADM and other departmental officials into hiring Mr. Charles, whom she had referred, an individual with no government or ATIP experience, at a management level for which departmental officials had advised he was not qualified. [i] The Office has interpreted the term “private interest" under the Act to refer largely to pecuniary interests. Subsection 2(1) of the Act provides a negative definition of the term, setting out that it “does not include an interest in a decision or matter (a) that is of general application; (b) that affects a public office holder as one of a broad class of persons; or (c) that concerns the remuneration or benefits received by virtue of being a public office holder." None of these exceptions apply in this matter. [ii] Morneau II Report [iii] Managing a conflict of interest: Why disclosing a friendship matters [iv] “Influence" in Black's Law Dictionary, 10th ed., at p. 898. [v] Trudeau II Report and The Finley Report

The Commissioner can start an investigation (called an examination) under the Conflict of Interest Act in one of two ways: When asked to investigate by a Senator or a Member of the House of Commons. They must provide reasonable grounds to believe that someone has contravened the Act.On his own initiative if he has reason to believe, based on information from members of the public or other sources, that someone has contravened the Act. When the Commissioner finishes an examination, he provides a report to the Prime Minister. That report is also made public. If he stops an examination that he started at the request of a Senator or Member, he must write a report (called a discontinuance report) explaining why. If he stops an examination that he started on his own, he doesn't have to write a report. Referrals from the Public Sector Integrity Commissioner The Public Sector Integrity Commissioner may refer matters to the Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act. Under section 68 of the Conflict of Interest Act, the Commissioner must issue a public report on each referral, whether he does an investigation or not.

Third quarter (October to December) – Overview of statistical data and conflict of interest compliance for MPs and public office holders. Third quarter of fiscal year 2025-2026 – October to December 2025 Individuals subject to conflict of interest regimes 343Members of the House of Commons1,289Reporting public office holders1,526Public office holders without reporting obligations (80 ministers and parliamentary secretaries, 668 ministerial staff,541 people appointed to other positions) (part-time members of federal boards,commissions and tribunals,and some part-time ministerial staff) Members of the House of Commons are elected. Public office holders are appointed. Conflict of interests prevention The Office helps Members of the House of Commons and Public office holders prevent conflicts of interests by: Members of the House of CommonsPublic office holdersContacting them as soon as they take office0 time 156 times Ensuring they complete the initial compliance process95 process183 processesGiving them advice109 times425 timesFollowing up with them every year0 reminders192 remindersPosting information in the public registry118 times371 timesTelling them about the post-employment rulesN/A124 times 50% of new reporting public office holders met all deadlines. The Office contacted new public office holders and MPs within 3 business days in 99% of cases. Confidential advice When a Member or a public office holder has questions, they ask advisors at the Office for confidential advice. Members received advice 109 timesPublic office holders received advice 425 timesGeneral obligations: 23%General obligations: 20%Material changes: 30%Material changes: 30%Gifts and other benefits: 25%Post-employment obligations: 19%Letters of support and fundraising: 22%Outside activities: 8% Gifts or other advantages: 23% The number of requests for advice was lower than the last quarter. The Office responded to standard requests within 3 business days in 90% of cases. Public registry The Office added information to the public registry: Members of the House of CommonsPostingsPublic office holdersPostingsDisclosure summaries 102Agreed compliance measures10Gifts and other benefits 8Assets46Material changes 6Gifts or other advantages92Sponsored travel2Liabilities50Private interest0Outside activities32Total118Recusals10 Summary statements130 Travel0 Other1 Total371 The volume of postings was higher compared to the last quarter. The public registry is updated daily and can be accessed online.You can search it by date, type of declaration, regime, or an individual's name.The information in the registry is the only information the Office can make public. 5,400 public registry visitors 34,700 public registry views After a Member leaves office, their information is removed from the registry. Post-employment rules (Conflict of Interest Act only) All public office holders are subject to some rules even after they leave their position. 124 public office holders left office this quarter Former reporting public office holders face extra rules for one or two years after they leave office (cooling-off period) 695 former public office holders were in their cooling-off period They can ask for an exemption, waiver, or reduction of their cooling-off period 1 exemption, waiver, or reduction granted Sanctions (Conflict of Interest Act only) 0 notices of violation sent Reporting public office holders who miss a reporting deadline may have to pay an administrative monetary penalty (fine). Before issuing a penalty, the Office sends them a notice of violation. No administrative monetary penalties were issued. Investigations (Act & Code) Case files opened and closed (a case file is a concern that is reviewed by the Office) 6 case files0 reports published5 case files closed Subject of new case filesSource of new case files3 ministers or parliamentary secretaries4 members of the general public1 Member of the House of Commons1 Member of the House of Commons2 public office holders0 media 1 within the Commissioner's Office 0 Office of the Public Sector Integrity Commissioner The Office's target is to finish investigations in 12 months. Education and outreach Requests from the publicRequests from the mediaSocial media983 requests*13 media requests12 X posts 960 outside mandate1 interview granted4,436 X followers23 within mandate5,200 media mentions 13,300 X mentions *See case files for investigation requests. 12 LinkedIn posts 1,225 LinkedIn followers WebsiteParliamentTraining and Education55,300 website visitors2 appearances12 presentations85,000 website views24% percentage of Question Periods where the Office was mentioned153 participants Responded to standard media requests within 4 hours in 100% of cases. Responded to standard public requests within 10 days in 93% of cases. To obtain the data used to produce this report, please contact us.

Investigation reports

Message from the Commissioner I am proud to introduce the Office of the Conflict of Interest and Ethics Commissioner's second accessibility plan. Recognizing that accessibility for all is a critical element of inclusion, the Office is taking action to eliminate barriers in its operations and service delivery in accordance with the Accessible Canada Act. This updated Accessibility Plan builds on the 2024 Progress Report and incorporates best practices from the 2023–2025 Accessibility plan. It outlines commitments to remove barriers across all priority areas under the Accessible Canada Act and introduces new elements such as culture, SMART objectives, and enhanced consultation processes. This law aims for the full and equal participation of all persons, especially persons with disabilities, in Canada. It recognizes that people are not disabled by their conditions, but instead by environments that are neither accessible, welcoming nor enabling. The Office's three-year plan maps out how we will improve accessibility in the seven key areas identified in the Accessibility Canada Act: employment; the built environment; information and communication technologies; communication; the procurement of goods, services and facilities; the design and delivery of programs and services; and transportation. It reflects the Office's commitment to create an accessible work environment and a diverse and inclusive workforce, as established in our Code of Values. As part of the Office's work towards identifying, preventing and eliminating accessibility barriers for our employees and stakeholders, we have held consultations to develop this plan. We welcome feedback at any time about accessibility at the Office to help us continue to identify, prevent and eliminate barriers and ensure use of best practices. The Office is committed to continuing its practice of publishing annual progress reports on accessibility and will publish a full Accessibility Report every third year, as required by the Accessible Canada Act. 1. General 1.1. Overview The Accessible Canada Act (ACA), which came into force in July 2019, aims to identify, remove, and prevent barriers to accessibility and make Canada barrier-free by January 1, 2040. In accordance with this law, the Office of the Conflict of Interest and Ethics Commissioner (Office) published its first accessibility plan in December 2022, and must update the plan every three years, showing how it identifies, removes, and prevents barriers. Each version must remain online for seven years after publication, and persons with disabilities must be consulted in its preparation. The plan must also describe the consultation process and be available in alternate formats upon request. This is the Office's second accessibility plan, building on the foundation established in the first plan and informed by lessons learned and feedback received. It reflects our ongoing commitment to continuous improvement and to embedding accessibility into all aspects of our operations. The plan addresses the seven priority areas described in section 5 of the ACA: EmploymentBuilt EnvironmentInformation and Communication Technologies (ICT)Communication (other than ICT)Procurement of Goods, Services, and FacilitiesDesign and Delivery of Programs and ServicesTransportation In developing this plan, the Office embraced the guiding principle of “Nothing without us", ensuring that persons with disabilities are actively engaged in identifying, preventing, and removing barriers.The plan also adheres to the principles set out in section 6 of the ACA: Everyone must be treated with dignity.Everyone must have the same opportunity to make for themselves the life they are able and wish to have.Everyone must be able to participate fully and equally in society.Everyone must have meaningful options and be free to make their own choices, with support if they desire.Laws, policies, programs, services, and structures must take into account the ways that different kinds of barriers and discrimination intersect.Persons with disabilities must be involved in the development and design of laws, policies, programs, services, and structures.Accessibility standards and regulations must aim to achieve the highest level of accessibility. 1.2. Statement of Commitment The Office remains committed to meeting all its obligations under the Accessible Canada Act and its regulations (the Accessible Canada Regulations). By establishing a working group on accessibility and by continuing to consult persons with disabilities, the Office is committed to the proactive identification, removal and prevention of barriers to accessibility at the workplace and in all aspects of its communications and activities. Accessibility neither begins nor ends with this plan; it is an ongoing process. We strive to continuously improve accessibility in everything we do. We are committed to creating a barrier-free environment for employees, stakeholders, and the public. ​ 1.3. Contact Information and Feedback Process The Office welcomes feedback, including feedback submitted anonymously, about accessibility at the Office and about this plan. We are committed to reviewing the feedback we receive in good faith and to taking steps to address, remove and prevent barriers to accessibility that are identified through this feedback. Feedback about either accessibility at the Office or this plan may be submitted in the following ways:​ By contacting the Office's Manager, Human Resources Client Services, Corporate Management, using the information below: Manager, Human Resources Client ServicesOffice of the Conflict of Interest and Ethics CommissionerParliament of CanadaOttawa, Ontario K1A 0A6AccessibleCIE@cie.parl.gc.ca613-995-0721 By completing the online accessibility feedback survey. Alternate formats of the survey can be requested by contacting accessibleCIE@cie.parl.gc.ca or 613-995-0721. The Office must keep the most recent version of the description of its feedback process for seven years after it is published or until a new description is published. The Office will acknowledge the feedback it received in the same way that it was sent to it, unless it was sent by an anonymous source. The Office will review all feedback received and take steps to address barriers to accessibility that are identified. A copy of any feedback received must be kept for seven years. We have been monitoring the Accessibility email inbox and there have been no accessibility matters that relate to accessibility at the Office. Alternative formats of this plan and/or a description of the feedback process, can be requested by contacting AccessibleCIE@cie.parl.gc.ca or 613-995-0721. In accordance with the regulations, the Office will provide the following alternative formats within 15 days of the initial request: PrintLarge print (increased font size) In accordance with the regulations, the Office will provide the following alternative formats within 45 days of the initial request: Braille (a system of raised dots that people who are blind or who have low vision can read with their fingers)Audio (a recording of someone reading the text aloud) 1.4. Definitions The following definitions apply throughout this plan: Barrier: means anything — including anything physical, architectural, technological or attitudinal, anything that is based on information or communications or anything that is the result of a policy or a practice — that hinders the full and equal participation in society of persons with an impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation. Disability: means any impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment — or a functional limitation — whether permanent, temporary or episodic in nature, or evident or not, that, in interaction with a barrier, hinders a person's full and equal participation in society. 1.5. About the Commissioner and the Office The Conflict of Interest and Ethics Commissioner administers the Conflict of Interest Act, a law that applies to public office holders and the Conflict of Interest Code for Members of the House of Commons, a code of conduct that applies to Members of Parliament that forms part of the rules of the House of Commons. These two regimes seek to prevent conflicts between private interests and the public duties of appointed and elected officials. The Commissioner also provides confidential advice to the Prime Minister about conflict of interest and ethics issues. The position of Conflict of Interest and Ethics Commissioner was created following the adoption of the Federal Accountability Act in 2006. The Commissioner is an Officer of the House of Commons whose mandate is set out in the Parliament of Canada Act. The Commissioner is completely independent of the government of the day and the Office is part of the parliamentary infrastructure. The Commissioner is supported by an Office of approximately 51 employees who occupy positions related to compliance, investigations, legal services, communications, and corporate management. 1.6. Compliance with future standards Accessibility Standards Canada is responsible for the development of accessibility standards for removing barriers to access faced by people with disabilities. These standards fall within the priority areas listed in the Accessible Canada Act. This organization publishes a database of standards and technical guides to support a barrier-free Canada. At the time of publication of this plan, 12 guides and standards have been published by Accessibility Standards Canada and made publicly available on their website. Others are in the process of being reviewed. At this time, the published standards and guides relate to areas of Procurement, Employment, Built Environment, Information and Communication Technologies, Communication, Transportation, Design and Delivery of Programs and Services, the Office is the process of reviewing these standards and others as they may apply to its plan and plan progress. 1.7. Accessibility goals and the Accessibility Working Group The aim of the Office is to complete the accessibility goals for each priority area described in Part 2 of this accessibility plan by the end of the year 2025. To achieve the accessibility goals and to implement the plan, the Office created an accessibility working group chaired by the Manager, Human Resources Client Services, Corporate Management, and comprised of employees from the various divisions of the Office. This working group will work closely with the Commissioner, the Senior Management Committee and the relevant directors of each division of the Office. In this way, timely approvals for the changes that will be necessary to give effect to the accessibility plan can be implemented within the deadline. The working group will also: monitor plan progress;work with the Office's Manager, Human Resources Client Services, Corporate Management, to receive, acknowledge and review feedback on accessibility;prepare the progress reports and update the accessibility plan; andconsult persons with disabilities. 2. Areas Described Under Section 5 of the Accessible Canada Act (ACA) 2.1. Employment 2.1.1. Overview This priority area is about the importance of ensuring access to employment opportunities and an accessible workplace. The Office is a separate employer whose employees are not part of the federal public administration. The Office has its own terms and conditions of employment, relating to hours of work, employee benefits and general working conditions affecting employees. Employees are not covered under any collective agreement. The Office has a Joint Labour Relations Committee, consisting of management and employee representatives to ensure that any new or revised policy, directive and guideline related to human resources management is developed in consultation with all employees of the Office. The Office is committed to employment equity and having a diverse and inclusive workforce. The Office's staffing processes and appointments are based on merit and are free from political influence. All employees of the Office are expected to follow the values set out in its Code of Values and Standards of Conduct which reflect its commitment to diversity and inclusion. The Office has adopted employment-related policies, in areas such as telework, occupational health and safety, procedures for emergency response, employee recognition, employee discipline, disability management and duty to accommodate, interchange Canada assignments, job shadowing, performance management, staffing procedures, training, termination and demotion, as well as on equity diversity and inclusion. The Office reviews and updates its policies and guidelines in line with those of other parliamentary entities and the wider public service.​ 2.1.2. Feedback When carrying out its consultations, the Office was mindful that barriers that may arise in the context of employment could include, but were not limited to, those encountered during staffing processes, onboarding, promotion and/or career progression, or during workplace accommodation. No barriers were identified in this area during consultation for this plan. Although during the last Employee satisfaction survey conducted in 2025, employees have expressed a lower level of satisfaction regarding the return to work premises compared to teleworking. 2.1.3. Accessibility Goals The Office will continue to support these ongoing accessibility goals through to the end of 2028. Review staffing tools, approaches, and policies to ensure that any barriers are identified and removed to make employment with the Office accessible and inclusive.Review the Office's Guideline on Disability Management and Duty to Accommodate.Continuously support the employee network groups, including the promotion of disability groups on the parliamentary Hill.Provide access to training sessions and information sessions for employees at all levels on accessibility, barriers, unconscious bias and accommodation requests and processes so they can build expertise. 2.2. The Built Environment 2.2.1. Overview This priority area is about the accessibility of the built environment which has a significant impact on whether people with disabilities can move freely, access and function within a space in a manner equitable with those who do not have disabilities. The primary location in which the Office conducts most of its activities is in downtown Ottawa at 66 Slater Street, Ottawa, Ontario on the 23rd floor. The Office has a Telework Policy. Employees must sometimes access other buildings and office spaces throughout the National Capital Region (NCR). At its primary location of work, the Office's lobby on the 23rd floor is accessed by using the building's elevators. There are also stairs that can be used from the building's ground floor to access the elevator lobby of the 23rd floor. Outside of the lobby, access to the office space requires use of a security card. There are washrooms, including an accessible washroom, on the 23rd floor. There are automatic doors located in some of the common areas such as washrooms and main entrances. The Office has also established and published Procedures for Emergency Response. Furthermore, when the Office relocated to the 23rd floor, it implemented accessible evacuation procedures and provided staff training to ensure the safety of persons with disabilities during emergencies. Since the last accessibility plan, the Office relocated to a newly redesigned floor on the 23rd Floor at 66 Slater Street in 2025. When carrying out the constructions, the Office was mindful of barriers that may arise in the built environment, such as stairs, steps, curbs, heavy or narrow doors, lack of automatic door openers, inaccessible washrooms, inadequate lighting, poor acoustics, and limited rest areas. The new space meets accessibility requirements and incorporates universal design principles. All elements of the built environment; including entrances, hallways, signage, washrooms, and emergency exits: meet or exceed current accessibility standards. Features of the new space include: Accessible washroom with wide entrance.Automatic doors throughout common areas and office spaces.Signage with braille and tactile elements for wayfinding.Improved sensory controls for lighting and acoustics to support diverse needs.Wider hallways to accommodate mobility devices and ensure barrier-free movement. This redesign demonstrates the Office's commitment to creating an inclusive and accessible workplace for all employees and visitors. 2.2.2. Feedback An employee working on Parliament Hill who has an expertise in accessibility and identifies as having a physical disability recently visited the Office’s new premises and provided valuable feedback on ways to reduce accessibility barriers. For example, relocating the signage for all three kitchen bins to the front would improve visibility, and adding Braille would benefit individuals with limited vision. Additionally, clearly defining the reception cubicle with contrasting color demarcation would assist people with vision impairments. These are useful suggestions that the Office will take into consideration moving forward. 2.2.3. Accessibility Goals The Office will continue to work on the following accessibility goals: Review and revisit accessibility as it relates to its built environment, including by making use of the accessibility feedback process, to ensure that new barriers have not been created and that existing accessibility features have been maintained.The OCIEC recognizes that fostering an accessibility-focused culture is essential for long-term success. This section outlines initiatives to embed accessibility into organizational values and behaviors in the built environment by adopting a fragrance-free environment. 2.3. Information and Communication Technologies (ICT) 2.3.1. Overview This priority area is about offering accessible digital content and technologies. Information and communication technologies are used to deliver and access information, perform activities, and provide services. They can include, but are not limited to, hardware, software, video or voice communication tools, and other digital content. In support of public education about the regimes that it administers, the Office makes a range of digital information available on its website (HTML and PDF) and is active on social media (X: @EthicsCanada). The Office also has a non-public facing website used by its employees, an intranet site based on the SharePoint platform. The Office is presently developing a new electronic system named “Nethik" to give appointed and elected persons who must comply with the regimes administered by the Office a fully secure, fast and easy way to submit required information to the Office. This system will also enhance the public registry of information that is made available by the Office to the public about certain private interests, gifts or travel. The Office, including its employees, also use email, Voice over Internet Protocol (VOIP), and software, such as MS Teams, to communicate and share information. The Office has contractual agreements and works with the House of Commons related to the provision of information technology. 2.3.2. Feedback When carrying out its consultation, the Office was mindful that barriers that may arise in the context of information and communication technologies could include, but were not limited to, electronic documents without accessibility features or alternative text, incompatibilities with screen readers or other assistive devices, and fonts or colour contrasts on web-based applications or in emails that create difficulties accessing the content. 2.3.3. Accessibility Goals The Office will aim to complete these accessibility goals by the end of 2028: Launch a new website that meets recognized accessibility standards, uses plain language, and is designed so all users can quickly and easily find the information they need. (medium term) 2.4. Communication, Other Than ICT 2.4.1. Overview This priority area focuses on ensuring that everyone can communicate, share, and access information without barriers. Accessible communication means using clear, direct, and inclusive language and offering information in formats that meet diverse needs. The Office communicates with elected and appointed public officials, the media, and the public through various channels, including phone, email, mail, fax, published reports and information notices on its website, social media (X and LinkedIn), as well as virtual and in-person presentations. The Office has established processes to ensure that information is accurate, timely, and useful. It is building on previous efforts to strengthen accessibility in communications by removing barriers to these interactions and by aligning with new standards. 2.4.2. Feedback When carrying out its consultation, the Office was mindful that barriers that may arise in the context of communication (other than ICT) could include, but were not limited to, font or print that is too small or hard to read, no alternative access to the content of graphs or charts, lack of use of plain language, instructions that are confusing or complicated, presentations that are not fully accessible, seating arrangements that exclude people from participating fully in the communication process. There was no feedback received in respect of the Office's Communication, Other Than ICT. 2.4.3. Accessibility Goals The Office will aim to complete these accessibility goals by the end of 2028. Align the Office's existing plain language practices with Canada's first National Standard on Plain Language (CAN-ASC-3.1:2025), published by Accessibility Standards Canada. (medium term)Improve the accessibility and readability of digital documents by updating the Office's default font to Aptos 12-point, which offers greater clarity on high-resolution screens and better character distinction. (short term)Implement a screen reader tool to test and optimize the accessibility of the Office's website and documents. (long term)Ensure the Office has clear guidance and resources to support accessibility features for presentations, such as closed captioning and sign language interpretation, when requested, and includes options for participants to request these services. (medium term) 2.5. Procurement of Goods, Services, and Facilities 2.5.1. Overview This priority area is about making accessibility an important component of the procurement process and about ensuring that the Office purchases accessible goods, services and facilities. Procurement refers to the acquisition of goods and services by any means, including purchase, rental, lease or conditional sale. For the Office, procurement is done in accordance with the Office's Directive on the Procurement of Goods and Services, Policy on the Delegation of Financial Signing Authorities, and the Directive on Acquisition Cards. The current procurement directive mentions an objective of enhancing access and includes a requirement for following ethical practices. As set out in its financial reports, the Office enters transactions with other government and parliamentary entities in the normal course of business and on normal trade terms. For example, the Office has agreements with the House of Commons related to the provision of information technology and security services, and the Public Services and Procurement Canada related to the provision of compensation services. 2.5.2. Feedback When carrying out its consultation, the Office was mindful that barriers that may arise in the context of procurement of goods, services, and facilities could include, but were not limited to whether a good or service can be used by persons in different positions (seated, standing), with different levels of strength or range of body movement, with hearing or vision loss; whether support materials, such as manuals, are accessible in other formats; whether products can be customized or work with other accessible technologies; whether the organization providing the good or service provide accessible customer support; whether there are accessibility requirement clauses set out in contracts or Office policies concerning contracting. There was no feedback received in respect of the Office's procurement. 2.5.3. Accessibility Goals The Office will aim to complete these accessibility goals by the end of 2028. Continuously review the current procurement directive and related policies to incorporate accessibility considerations.Continuously review the inventory of current goods and services and enquire about the accessibility practices and services of current suppliers. 2.6. Design and Delivery of Programs and Services 2.6.1. Overview This priority area is about ensuring that everyone can receive and access the services and programs delivered by the Office. The key programs and services delivered by the Office involve: reporting to the Prime Minister and to Parliament;helping regulatees achieve and maintain compliance with the conflict of interest regimes;giving regulatees confidential guidance tailored to their individual situations;helping regulatees understand their obligations under the regimes through education and outreach;applying investigations and other enforcement provisions as appropriate;exchanging information with domestic and international counterparts;providing programs and services to employees. 2.6.2. Feedback When carrying out its consultations the Office was mindful that barriers that may arise in the context of design and delivery of programs and services could include, but were not limited to a lack of diverse channels for delivering services (e.g., over the phone, in-person, email, reports). The Office received no feedback in this area. 2.6.3. Accessibility Goals The Office will aim to complete this accessibility goal by the end of 2028. Provide employees with appropriate tools and training to make accessibility a key consideration in all future programs and services. 2.7. Transportation 2.7.1. Overview This priority area aims to create a barrier-free federal transportation network. While the Office does not provide transportation services, travel on behalf of the Office may from time-to-time form part of an employee's official duties. In this context, the Office has Guidelines on Travel that consider accessibility, as well as a Directive on Travel and Conference. Expenditures, Guidelines for the Approval of Travel for the Conflict of Interest and Ethics Commissioner, the National Joint Council Travel Directive, the Code of Values and Standards of Conduct for employees of the Office and other internal policies or directives related to financial management. The primary place of work for the Office, 66 Slater Street, is located in downtown Ottawa. It is accessible by public transit and the building has underground public parking operated and managed by a third party and includes access to the building's elevators. Parking is also available at the National Arts Centre across the street from the building. The Office has guidelines on parking and the use of parking passes by employees. As a result of its location, offloading and onloading from vehicles as well as vehicle passenger drop-off or pick-up can be challenging outside of the building. 2.7.2. Feedback When carrying out its consultations, the Office was mindful that barriers that may arise in the context of transportation could include, but were not limited to those that result from long work-related travel distances, adverse policies affecting travel, lack of accessible seating, alternative service options, lack of or confusing signs and directions. The Office received no feedback in this area. ​ 2.7.3. Accessibility Goals Review policies and guidelines related to employee travel to identify and remove any accessibility barriers to ensure that all employees travel safely regardless of disability.Update guidelines on parking and the use of parking passes by employees to include accessibility standards, including as to how parking spaces are attributed. 3. Consultations Since the initial plan was published, employees at all levels of the Office were consulted for the purposes of informing this accessibility plan. Through these consultations, each person was offered the opportunity to provide anonymized accessibility feedback through a survey in the areas described under section 5 of the Accessible Canada Act. They were also provided with an alternative method for contacting the Office with questions or comments about accessibility. ​ 3.1. Employees As part of its commitment to continuous improvement, the Office conducts an Employee Satisfaction Survey every three years, and the most recent survey was completed this year. The survey provided employees with an opportunity to share feedback on various aspects of their work environment, level of satisfaction and possibility of providing suggestions. No comments or concerns related to accessibility preferences, barriers, or accommodation needs were identified during this process. This result indicates that employees are generally satisfied with their work environment, and no accessibility-related issues were raised. The Office will continue to monitor employee feedback and maintain open channels for accessibility-related input to ensure that emerging needs are addressed promptly. 3.2. Stakeholders The Office consulted the House of Commons and its experts on accessibility to ensure full compliance with accessibility standards on the development of its website. There were also accessibility experts from the House of Commons who were consulted during the construction of the built environment, i.e. the 23rd floor and move. 3.3. Public In developing this plan and after its move to the 23rd floor, the Office consulted a person who identifies as having a physical disability. The individual came to the built environment and was kind enough to provide great advice, feedback and resources concerning barriers and accessibility about the physical environment. The feedback offered was generally positive with some focus area for improvement. Most were related to eyesight limitations or moving small office furniture and equipment. The Objective for the Accessibility Plan will consider the recommendations made during this consultation. 3.4. Parliamentary Precinct Working Group Over the past years, the Office regularly participated in bi-weekly meetings on accessibility with representatives of other parliamentary precinct entities. The purpose of these meetings is to share experiences, share feedback on consultations with persons with disabilities who have had dealings with parliamentary entities and advocacy groups, and to share information to help align an approach to accessibility by parliamentary entities. The information shared at this working group was greatly appreciated and was instrumental in the preparation of this plan.​

Second quarter (July to September) – Overview of statistical data and conflict of interest compliance for MPs and public office holders. Second quarter of fiscal year 2025-2026 – July to September 2025 Individuals subject to conflict of interest regimes 343Members of the House of Commons1,282Reporting public office holders1,555Public office holders without reporting obligations (79 ministers and parliamentary secretaries, 636 ministerial staff,567 people appointed to other positions) (part-time members of federal boards,commissions and tribunals,and some part-time ministerial staff) Members of the House of Commons are elected. Public office holders are appointed. Conflict of interests prevention The Office helps Members of the House of Commons and Public office holders prevent conflicts of interests by: Members of the House of CommonsPublic office holdersContacting them as soon as they take office1 time 192 times Ensuring they complete the initial compliance process56 process64 processesGiving them advice170 times569 timesFollowing up with them every year0 reminders166 remindersPosting information in the public registry93 times345 timesTelling them about the post-employment rulesN/A87 times 40% of new reporting public office holders met all deadlines. The Office contacted new public office holders and MPs within 3 business days in 80% of cases. Confidential advice When a Member or a public office holder has questions, they ask advisors at the Office for confidential advice. Members received advice 170 timesPublic office holders received advice 569 timesGeneral obligations: 58%General obligations: 42%Material changes: 9%Material changes: 16%Gifts and other benefits: 16%Post-employment obligations: 23%Letters of support and fundraising: 1%Outside activities: 8% Gifts or other advantages: 11% The number of requests for advice was higher than the last quarter. The Office responded to standard requests within 3 business days in 87% of cases. Public registry The Office added information to the public registry: Members of the House of CommonsPostingsPublic office holdersPostingsDisclosure summaries 64Agreed compliance measures4Gifts and other benefits 5Assets32Material changes 1Gifts or other advantages45Sponsored travel5Liabilities32Private interest0Outside activities22Total75Recusals4 Summary statements60 Travel0 Other0 Total199 The volume of postings was higher compared to the last quarter. The public registry is updated daily and can be accessed online.You can search it by date, type of declaration, regime, or an individual's name.The information in the registry is the only information the Office can make public. 12,000 public registry visitors 97,00 public registry views After a Member leaves office, their information is removed from the registry. Post-employment rules (Conflict of Interest Act only) All public office holders are subject to some rules even after they leave their position. 179 public office holders left office this quarter Former reporting public office holders face extra rules for one or two years after they leave office (cooling-off period) 644 former public office holders were in their cooling-off period They can ask for an exemption, waiver, or reduction of their cooling-off period 1 exemption, waiver, or reduction granted Sanctions (Conflict of Interest Act only) 1 notice of violation sent Reporting public office holders who miss a reporting deadline may have to pay an administrative monetary penalty (fine). Before issuing a penalty, the Office sends them a notice of violation. Administrative monetary penalties One $200 penalty paid for failing to disclose a material change relating to assets. All penalties are posted in the public registry. Investigations (Act & Code) Case files opened and closed (a case file is a concern that is reviewed by the Office) 3 case files0 reports published7 case files closed Subject of new case filesSource of new case files0 minister or parliamentary secretary3 members of the general public1 Member of the House of Commons0 Members of the House of Commons2 public office holders0 media0 persons not subject to Act or Code0 within the Commissioner's Office 0 Office of the Public Sector Integrity Commissioner The Office's target is to finish investigations in 12 months. Education and outreach Requests from the publicRequests from the mediaSocial media261 requests*47 media requests14 X posts 221 outside mandate0 interviews granted4,401 X followers40 within mandate4,000 media mentions 9,800 X mentions *See case files for investigation requests. 14 LinkedIn posts 1,200 LinkedIn followers WebsiteParliamentTraining and Education53,000 website visitors1 appearance11 presentations90,000 website views10% percentage of Question Periods where the Office was mentioned171 participants Responded to standard media requests within 4 hours in 100% of cases. Responded to standard public requests within 10 days in 93% of cases. To obtain the data used to produce this report, please contact us.

First quarter (April to June) – Overvie First quarter of fiscal year 2025-2026 – April to June 2025 Individuals subject to conflict of interest regimes 342Members of the House of Commons1,069Reporting public office holders1,743Public office holders without reporting obligations (79 ministers and parliamentary secretaries, 420 ministerial staff,570 people appointed to other positions) (part-time members of federal boards,commissions and tribunals,and some part-time ministerial staff) Members of the House of Commons are elected. Public office holders are appointed. Conflict of interests prevention The Office helps Members of the House of Commons and Public office holders prevent conflicts of interests by: Members of the House of CommonsPublic office holdersContacting them as soon as they take office343 times 132 times Ensuring they complete the initial compliance process9 process127 processesGiving them advice72 times551 timesFollowing up with them every year0 reminders195 remindersPosting information in the public registry19 times143 timesTelling them about the post-employment rulesN/A275 times 37% of new reporting public office holders met all deadlines. The Office contacted new public office holders and MPs within 3 business days in 97% of cases. Confidential advice When a Member or a public office holder has questions, they ask advisors at the Office for confidential advice. Members received advice 72 timesPublic office holders received advice 551 timesGeneral obligations: 61%General obligations: 20%Material changes: 10%Material changes: 19%Gifts and other benefits: 28%Post-employment obligations: 31%Letters of support and fundraising: 1%Outside activities: 25% Gifts or other advantages: 5% The number of requests for advice was lower compared to the last quarter. The Office responded to standard requests within 3 business days in 84% of cases. Public registry The Office added information to the public registry: Members of the House of CommonsPostingsPublic office holdersPostingsDisclosure summaries 14Agreed compliance measures4Gifts and other benefits 2Assets18Material changes 0Gifts or other advantages41Sponsored travel3Liabilities4Private interest0Outside activities22Total19Recusals6 Summary statements42 Travel1 Other0 Total138 The volume of postings was lower compared to the last quarter. The public registry is updated daily and can be accessed online.You can search it by date, type of declaration, regime, or an individual's name.The information in the registry is the only information the Office can make public. 4,200 public registry visitors 48,130 public registry views After a Member leaves office, their information is removed from the registry. Post-employment rules (Conflict of Interest Act only) All public office holders are subject to some rules even after they leave their position. 275 public office holders left office this quarter Former reporting public office holders face extra rules for one or two years after they leave office (cooling-off period) 571 former public office holders were in their cooling-off period They can ask for an exemption, waiver, or reduction of their cooling-off period 0 exemptions, waivers, or reductions granted Sanctions (Conflict of Interest Act only) 3 notices of violation sent Reporting public office holders who miss a reporting deadline may have to pay an administrative monetary penalty (fine). Before issuing a penalty, the Office sends them a notice of violation. Administrative monetary penalties Two $200 penalties paid for failing to disclose a material change relating to assets. One $200 penalty paid for failing to submit a Confidential Report within 120 days of appointment. All penalties are posted in the public registry. Investigations (Act & Code) Case files opened and closed (a case file is a concern that is reviewed by the Office) 12 case files (new and carried over)0 reports published8 case files closed Subject of new case filesSource of new case files9 minister or parliamentary secretary0 members of the general public1 Member of the House of Commons10 Members of the House of Commons2 public office holders0 media0 persons not subject to Act or Code1 within the Commissioner's Office 1 Office of the Public Sector Integrity Commissioner The Office's target is to finish investigations in 12 months. Education and outreach Requests from the publicRequests from the mediaSocial media167 requests*39 media requests6 X posts 129 outside mandate0 interviews granted4,387 X followers38 within mandate3,860 media mentions 5,268 X mentions *See case files for investigation requests. 8 LinkedIn posts 1,120 LinkedIn followers WebsiteParliamentTraining and Education52,900 website visitors0 appearance11 presentations104,500 website views35% percentage of Question Periods where the Office was mentioned169 participants Responded to standard media requests within 4 hours in 95% of cases. Responded to standard public requests within 10 days in 73% of cases. To obtain the data used to produce this report, please contact us.

The Office of the Conflict of Interest and Ethics Commissioner is committed to transparency in its operations. It proactively discloses the Commissioner’s and employees' travel and hospitality expenses, the Office’s contracts over $10,000, and its annual financial statements. By September 30 each year, it posts financial statements for the previous fiscal year on this website. There is also information about the Office’s resources in its Financial statements. Proactive disclosureContractsHospitalityTravel Q1 - April to JuneQ1 - April to JuneQ1 - April to JuneQ2 - July to SeptemberQ2 - July to SeptemberQ2 - July to SeptemberQ3 - October to DecemberQ3 - October to DecemberQ3 - October to DecemberQ4 - January to MarchQ4 - January to MarchQ4 - January to March

This report summarizes the Office’s work in administering the Conflict of Interest Act. That work includes compliance activities, education and outreach initiatives, and investigations. Commissioner's message I am pleased to report on the administration of the Conflict of Interest Act in 2024-2025. This was my first full fiscal year as part of my seven-year mandate as Commissioner. The activities reported here reflect the approach taken by the Commissioner’s Office in the last year. That approach focuses on our mandate, and it supports three key objectives. One, foster public confidence that the actions of elected and appointed federal officials are free from conflicts of interest. Two, help public officials manage their conflicts of interest so the most competent and qualified people can move in and out of public service without any problems. Three, examine and report on allegations of conflicts of interest that involve elected or appointed federal officials. In 2024-2025, we published three investigation reports under the Conflict of Interest Act and reviewed over a dozen case files. The Commissioner’s Office uses various tools to achieve these objectives, including one-on-one interface with each elected or appointed official, training and educational resources, and our website. The Conflict of Interest Act strikes a balance between confidentiality, to protect public office holders’ privacy, and maximum transparency, to support accountability. We apply both these concepts in our work. Confidentiality ensures public office holders can freely and openly share their issues with us. Transparency allows us to be as open as possible with Parliament and the public about everything the Commissioner’s Office does. Everyone should understand what we are doing and why we are doing it. This helps ensure the credibility of the Act and its administration. The Commissioner’s Office is committed to being efficient and making decisions quickly. When there are allegations of wrongdoing, quick resolutions are essential as reputations may be at stake. Building on the work of the previous year and the principles identified above, we have developed a five-year strategic plan. We look forward to implementing this approach in the upcoming years and meeting new challenges. Vision, mission and mandate Vision To safeguard public confidence in the integrity of Parliament and government institutions. Mission To help elected and appointed public officials avoid conflicts of interest. Mandate Administer the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act so as to manage conflicts of interest. The Commissioner’s Office has identified four priorities in its 2025-2030 Strategic Plan to advance its vision, mission, and mandate: Avoiding conflicts of interest Improve processes and resources to help public officials manage conflicts of interests efficiently, while supporting transparency and accountability. User-friendly experience Ensure every interaction with public officials is positive, seamless and user-focused, engendering trust and satisfaction. Healthy and fulfilling workplace Foster a healthy, inclusive work environment where employees always act with integrity. Support diversity, professional development, and hybrid work. Tools, knowledge, and skills Give employees modern tools and training so they have the knowledge and skills to effectively carry out the mandate of the Commissioner’s Office. Fostering public confidence A key objective of the Commissioner’s Office is to help Canadians trust that the actions of elected and appointed public officials at the federal level are free from conflicts of interest. Canadians must feel confident that those officials do not use their public office for private gain. The things they do in their jobs should be to benefit the public, not themselves or someone they know. Competing interests must not interfere with their ability to be fair and objective. Everything the Commissioner’s Office does—from advising public officials to reporting to Parliament—ultimately aims to foster this public confidence. This report highlights how it works to build public trust in the activities of public office holders, who are all subject to the Conflict of Interest Act. This group consists mainly of federal officials appointed to their positions by the Governor in Council (the Governor General acting on the advice of Cabinet) or a minister. Some of them must follow only the Act’s general rules. These public office holders without reporting obligations are mostly part-time members of federal boards, commissions and tribunals, and ministerial staff who work on average less than 15 hours a week. The rest, mostly full-time officials, must follow extra rules under the Act. These reporting public office holders include ministers, ministers of state (who may be called “secretaries of state”) parliamentary secretaries, ministerial staff who work on average 15 hours or more a week, and some senior public servants. Snapshot of all public office holders subject to the Act as of March 31, 2025 - 2,868 Reporting public office holders - 1,329Public office holders without reporting obligations - 1,539 25 ministers 0 parliamentary secretaries* 721 ministerial staff 583 Governor-in-Council appointees 1,539 part-time members of federal boards, commissions and tribunals and some ministerial staff The number of people subject to the Act went up and down during the year.*When Parliament is dissolved for a general election, parliamentary secretaries lose their positions Turnover among public office holders in 2024-2025Newly appointed or reappointedLeft officeReporting public office holders320419Public office holders without reporting obligations410181Total730600 Confidentiality and transparency The complementary concepts of keeping things private and being open are key to the work of the Commissioner’s Office. Confidentiality encourages public officials to communicate freely and openly with the Commissioner’s Office, and to ask it for advice when faced with a situation that may put them in a conflict of interest. When public officials disclose information to the Commissioner’s Office, other than statutorily protected information, most of it is kept confidential. The Office uses this information to help them arrange their affairs to avoid conflicts of interest, and to make sure they are following the rules. The Conflict of Interest Act has strict confidentiality requirements. These allow public office holders to fully disclose their situation so the Commissioner can give them advice based on complete information. All their interactions with the Commissioner’s Office are confidential and can only be made public by the public office holders themselves, not by the Office. Transparency is a keystone for fostering public confidence. It is built into the Act through its public declaration requirements. Some of the information that reporting public office holders disclose to the Commissioner’s Office must be posted in a public registry for anyone to see. The public registry is a searchable database that can be accessed through the Office’s website. It contains all the information about public officials that the Commissioner is allowed to make public. Public registry activitiesPostingsViews2024-20251,316170,628Five-year average1,261101,438 Reporting public office holders’ information stays in the public registry until the end of their cooling-off period under the Act’s post-employment rules. The Commissioner’s Office is transparent about its own activities. It publishes quarterly statistical reports that contain data on what it is doing and how it is meeting its service standards. Reporting to Parliament The Commissioner has a duty to report to Parliament, testify before parliamentary committees, and answer questions from Parliament. As an independent Officer of the House of Commons, he reports to Parliament directly, not through a minister. By June 30 each year, the Commissioner sends a report on the administration of the Conflict of Interest Act to the Speakers of the Senate and the House of Commons for tabling. The Commissioner’s Office sends communiqués to parliamentarians about its reports and other activities. It sent four of these in 2024-2025. The House of Commons Standing Committee on Access to Information, Privacy and Ethics has oversight responsibility for the Commissioner’s Office. The Committee reviews its annual spending estimates, and matters related to the Commissioner’s reports under the Act. Committee appearances in 2024-2025 DateDescriptionApril 16, 2024 House of Commons Standing Committee on Access to Information Privacy and Ethics, Main Estimates 2024-2025 Commissioner Konrad von Finckenstein appeared with Sandy Tremblay, Director, Corporate Management Melanie Rushworth, Director, Communications, Outreach and Planning June 4, 2024 House of Commons Standing Committee on Access to Information Privacy and Ethics, Compliance of a Minister with the Conflict of Interest Act Commissioner Konrad von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance August 8, 2024 Standing Committee on Public Accounts Report 1, ArriveCAN of the 2024 Reports of the Auditor General of Canada Commissioner Konrad von Finckenstein appeared with Michael Aquilino, Legal Counsel September 16, 2024 Standing Committee on Industry and Technology Recent Investigation and Reports on Sustainable Development Technology Canada Commissioner Konrad von Finckenstein appeared with Michael Aquilino, Legal Counsel September 17, 2024 Standing Senate Committee on National Finance Main Estimates 2024-2025 Commissioner Konrad von Finckenstein appeared September 16, 2024 House of Commons Standing Committee on Procedure and House Affairs Forms and Procedural and Interpretative Guidelines from the Conflict of Interest and Ethics Commissioner (in camera meeting) Commissioner Konrad von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance October 21, 2024 House of Commons Standing Committee on Public Accounts Report 6, Sustainable Development Technology Canada, of the 2024 Reports 5 to 7 of the Auditor General of Canada Commissioner Konrad von Finckenstein appeared with Michael Aquilino, Legal Counsel Proposed amendments During some of these appearances, the Commissioner was asked if there were any legislative changes he would recommend. Drawing on his experience, he has proposed amendments to the Parliament of Canada Act, under which the Commissioner is appointed, and the Conflict of Interest Act, which he administers. They would help the Commissioner’s Office function more effectively, and administer the Act more efficiently. The wording of these proposed amendments can be consulted in Appendix B. Appointment of an interim Commissioner Amend the Parliament of Canada Act to allow the Commissioner of Lobbying of Canada to temporarily take over the duties of the Conflict of Interest and Ethics Commissioner when no interim or permanent Commissioner has been appointed. Under subsection 82(2) of this Act, if the Commissioner is absent, unable to perform their duties, or leaves the position, the Governor in Council may appoint a qualified person to temporarily fill the role for up to six months. This can take a long time. While the Commissioner’s Office can keep managing the day-to-day tasks of administering the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons, there are some things it cannot do. For example, a Commissioner’s authority is needed to conduct investigations, reimburse blind trust costs, approve compliance measures, issue administrative monetary penalties, and waive or shorten cooling-off periods. Adding apparent conflicts of interest Include apparent conflicts of interest in public office holders’ general duty, set out in section 5 of the Act, to arrange their private affairs in a manner that will prevent all forms of conflicts of interest. The recommendation to amend the Act to incorporate the appearance of conflict was proposed, perhaps most notably, in the 2010 report of the Oliphant Commission. In that report, Commissioner Oliphant noted that an apparent conflict of interest is understood to exist if “there is a reasonable perception, which a reasonably well-informed person could properly have, that a public office holder’s ability to exercise an official power or perform an official duty or function will be, or must have been, affected by his or her private interest or that of a relative or friend.” The Conflict of Interest Code for Members of the House of Commons requires Members to avoid both real and apparent conflicts of interest. Similar language is used in the Values and Ethics Code for the Public Sector, which governs the conduct of all federal public servants. The Commissioner is of the view that public office holders should not be subject to a less stringent standard of conduct than parliamentarians and public servants. As the Supreme Court of Canada has observed, integrity in the democratic process can be harmed just as easily by the appearance of impropriety as by the actual impropriety. Review of exempt and controlled assets Amend the Conflict of Interest Act to allow the Governor in Council, on the Commissioner’s recommendation, to designate certain types of assets as exempt assets under the Act if the Commissioner believes they pose no risk of conflict of interest. Section 20 of the Act lists assets that reporting public office holders are not allowed to own (called “controlled assets”) and those that are exempt from any compliance measure (“exempt assets”). Controlled assets are assets whose value could be directly or indirectly affected by government decisions or policy, like publicly traded securities. Since the Act came into force in 2007, many new investment assets and vehicles have entered the market, like tax-free savings accounts (TFSAs), exchange-traded funds (ETFs) and cryptocurrencies. The Commissioner has no discretion to exempt assets that pose little risk of conflict of interest, like an ETF that is not managed by a reporting public office holder. Harmonize the definitions of “private interest” Align the Act’s definition of private interest with the definition in the Conflict of Interest Code for Members of the House of Commons. Under the Code, a Member is not considered to be furthering private interests if the matter in question affects them or any other person as one of a broad class of the public. Under the Act, a similar exclusion for matters that affect the interests of a broad class of persons refers only to the public office holder, not to other persons. The proposed change to the Act would clarify that public office holders can participate in matters involving the private interests of their friends or relatives, if those interests are the same as those of other members of the broad class they are part of. Expanding allowed outside activities Give the Commissioner the discretion to allow reporting public office holders to engage in any outside activities that the Commissioner believes would not cause a conflict of interest with their official duties. The Act restricts the activities of reporting public office holders that are not part of their official duties. For example, they are not allowed to have a job, practise a profession, manage or operate a business or commercial activity, or sit on a board of directors. There are three limited exceptions that allow them to engage in certain outside activities if the Commissioner believes these would not cause a conflict of interest. However, there are no exceptions for many other activities that may not cause a conflict, like teaching part-time at a university. Increasing administrative monetary penalties Increase the maximum amount of administrative monetary penalties to $3,000 to underscore the importance of meeting the Act’s reporting requirements. The Commissioner can impose administrative monetary penalties of up to $500 on reporting public office holders who do not meet administrative reporting deadlines. Although this provision aims to encourage compliance rather than to punish, it is not an effective incentive because the amount is so low. Too many public office holders continue to contravene the most basic compliance rules on timely and accurate filing of reports and material changes to their interests, or treat it as a minor task that can be ignored. Public communications In support of transparency, the Commissioner’s Office communicates as openly with the public as it is allowed to under the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. It shares as much information as it can, and in different ways. For example, it posts information on its website. Website usage2024-2025Users127,500Page views280,000 This year, the website attracted twice as many users and had twice as many page views as the year before. Website traffic rose in the last two quarters. The Commissioner’s Office designed and built a new website so different users can quickly and easily find the information they are looking for. The content is written in plain language to make it more accessible. The website will be launched in 2025-2026. The Commissioner’s Office uses social media to share information about its activities and updates from the public registry that may be of interest to journalists, academics, Canadian and international ethics practitioners, and others. Social media usageX@EthicsCanada@ÉthiqueCanada LinkedIn @ethics-ethique-canada Posts7980Followers4,3571,052 It responds to journalists and members of the public who seek information by telling them as much as possible about how the Act and the Code work, and directing them to the public registry when appropriate. Media inquiries in 2024-2025Public inquiries in 2024-2025 114 emails and and phone calls from members of the media Over 85% were questions about a specific elected or appointed official, or the status of a current case fileAbout 10% were general inquiries about the Office’s role and mandate5% were about the Commissioner’s investigation reports 400 emails and phone calls from members of the public 80% did not fall within the Commissioner’s mandate and were redirected20% were general inquiries about the role of the Office or complaints about a particular official. Some were shared with the Investigations division for follow-up The Commissioner’s Office also gives presentations about its work to interested audiences that in 2024-2025 included: Dalhousie University, Ethics in Action courseCarleton University, Ethics in Political Management courseMany Facets of Parliament, a seminar for parliamentary employeesMontreal Integrity Network, a network of professionals who help organizations develop ethics and compliance programs Connecting with others The Commissioner's Office works with other organizations to stay updated on and share best practices. This collaboration supports its objective of fostering public confidence that elected and appointed officials’ actions are free from conflicts of interests. It continues to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN) of federal, provincial, and territorial conflict of interest commissioners. In September 2024, the Commissioner, a Legal Counsel and the Director of Communications, Outreach and Planning attended CCOIN’s annual meeting, hosted by Ethics Commissioner Ariane Mignolet in Quebec City. The Commissioner’s Office is a member of the Ethics Practitioners Association of Canada (EPAC). With members from government, business, voluntary sector, and the academic community, EPAC promotes ethical practices in organizations, and supports ethics practitioners across Canada. It is an active member of two international ethics organizations. The Réseau francophone d’éthique et de déontologie parlementaires (RFEDP) promotes exchanges between parliaments and entities in the Organisation internationale de la Francophonie [link in French only] that are interested in ethics and codes of conduct. RFEDP activities in 2024-2025: The Commissioner, the Director of Advisory and Compliance, and the Director of Communications, Outreach and Planning participated in its 2024 Annual General Meeting, held in Brussels. As a member of the RFEDP’s Bureau, the Director of Advisory and Compliance participated in a May 2024 seminar in French Polynesia as a speaker and moderator. It was part of an ongoing RFEDP project to train parliamentarians in the Francophonie on avoiding conflicts of interest. In July, she attended a meeting of the Bureau in Montreal, while participating in bilateral discussions and committee meetings during the annual meeting of the Assemblée parlementaire de la Francophonie [link in French only]. The Council on Governmental Ethics Laws (COGEL) is a U.S.-based organization of government ethics practitioners. COGEL activities in 2024-2025: Office representatives attended COGEL’s 2024 conference, held in Los Angeles in December 2024, and joined several virtual events during the year. Other international outreach activities: In May 2024, the Commissioner’s Office gave input to Global Affairs Canada for its response to a questionnaire on the G20 Anti-Corruption Working Group Accountability Report. In March 2025, an Office representative attended the 2025 OECD Global Anti-Corruption and Integrity Forum​ (hosted by the Organisation for Economic Co-operation and Development). Helping appointed officials manage conflicts of interest Another key objective of the Commissioner’s Office is to help public officials manage their potential conflicts of interest so the most competent and qualified people can move in and out of public service without any problems. This reflects two of the Conflict of Interest Act’s purposes: to encourage experienced and competent people to seek and accept public office, andto facilitate interchange between the private and public sectors. When it appoints people from the private sector to federal positions, the Government of Canada benefits from a broad range of skills, experiences, and perspectives. Like all experienced people, these individuals may face potential conflicts between public and private interests. The Commissioner’s Office helps public office holders avoid and manage conflicts of interest by giving them information about the Act’s rules. It also guides them on how to follow those rules and submit required information. In August 2024, the Commissioner’s Office reported publicly on its January 2024 survey of public office holders. The results continue to guide how it communicates and engages with them. Communications with public office holders in 2024-2025 308 emails outlining rules and obligations sent to new and reappointed public office holders without reporting obligations 422 emails outlining rules and obligations sent to new and reappointed reporting public office holders Personal advice The Commissioner’s Office helps appointed officials follow the rules that apply to them, by giving them information and advice when they need it, and by answering their questions promptly. It assigns each reporting public office holder an advisor who works with them throughout their time in office. Their advisor helps them understand and follow the rules and meet the Act’s reporting requirements. Reporting public office holders can ask their advisor for advice at any time. The Commissioner’s Office aims to contact each reporting public office holder personally within three days after learning of their appointment. Public office holders without reporting obligations are not assigned their own advisors, but are welcome to speak with an advisor when they have questions. The Commissioner’s Office gives them information about the Act when they are appointed. Around the end of their term, it tells them about the post-employment rules they must follow. It also communicates with them while they are in office and invites them to educational sessions. Breakdown of advice by topic2024-2025Gifts or other advantages294Outside activities545Post-employment obligations439Material changes678General obligations720Total2,676 To make sure the advice it gives public office holders is consistent, the Commissioner’s Office tracks the topics they ask about, so it can identify training needs and spot trends that might impact its workload. When asked, the Office explains the Act’s requirements to candidates for federal appointments. Guidance on reporting requirements Advisors walk newly appointed reporting public office holders through the initial compliance process under the Act, which must be completed within 120 days after their appointment. It is an opportunity for them to familiarize themselves with the rules and address potential issues. Step 1: Each reporting public office holder must give the Commissioner’s Office detailed personal and financial information about themselves and their family, by filling out a Confidential Report within 60 days after their appointment. Step 2: Their advisor reviews this information and helps them organize their affairs to avoid conflicts of interest. For example, the reporting public office holder might have controlled assets (assets, like publicly traded securities, whose value could be affected by government decisions or policy) that the Act does not let them own. Their advisor can guide them on how to divest (get rid of) those assets. They must sell them in an arm’s-length transaction (where there is no special or close connection between them and the buyer), or put them in a blind trust (transfer them to someone to hold and manage so they do not know how their money is being invested). The Commissioner’s Office can help them get reimbursed (paid back) for the trust’s administrative costs.​ Helping reporting public office holders arrange their affairs to avoid conflicts of interests 422 initial compliance processes completed 2,676 instances of advice provided 812 public registry postings (includes postings related to initial compliance and ongoing reporting requirements)80% of reporting public office holders submitted their initial compliance information on time. Of the rest, more than half submitted it within one week of the deadline.9 conflict of interest screens set up46 divestments of controlled assets (34 by sale and 12 by blind trust)157 reimbursement orders issued for blind trust fees totalling $911,078​ In October 2024, the Commissioner delegated to advisors the authority to approve minimal value exemptions for controlled assets. Under subsection 27(10) of the Act, reporting public office holders who are not ministers or parliamentary secretaries may be allowed to keep some controlled assets if they are of such minimal value (up to $60,000) that they do not pose any risk of conflict of interest in relation to their official duties and responsibilities. Reporting public office holders might also have to quit certain outside activities (activities that are not part of their official duties) that the Act does not allow. Their advisor can also help them set up a conflict of interest screen. A screen is a formal plan that enables them to avoid handling files that could put them in a conflict of interest. Step 3: The advisor prepares a summary of the information in the Confidential Report. The reporting public office holder must review, sign and return this Summary Statement. Step 4: The Commissioner’s Office posts the Summary Statement in the public registry, and the initial compliance process is over. The Commissioner’s Office helps reporting public office holders meet other reporting requirements during their whole time in public office. They must tell it about the following things, within certain deadlines. Some of this information is made public. Material changes. Any changes to the information in their Confidential Report.Gifts or other advantages that they or their family members accept. They must publicly declare multiple gifts received from one source in a 12-month period with a total value of $200 or more, within 30 days after the value reaches $200 or more.Private flights (on non-commercial chartered or private aircraft) accepted by ministers, ministers of state or parliamentary secretaries for themselves, members of their family, or ministerial staff or advisers. The relevant minister, minister of state or parliamentary secretary must publicly declare them.Recusals. When they stepped back from a discussion, a decision, a debate or a vote on anything they might have a conflict of interest in.Firm offers of outside employment. Outside employment does not include jobs or contracts with federal government entities or federal parliamentary entities.Acceptance of offers of outside employment. Reporting public office holders must also complete an annual review. Each year, they must go over their information with their advisor in the Commissioner’s Office, and update it as needed. In 2024-2025, over 1,000 annual reviews were completed. Public declarations by reporting public office holders in 2024-20252024-2025Agreed compliance measures25Assets100Gifts or other advantages151Liabilities31Outside activities176Recusals40Summary statements257Travel3Post-employment exemption, waiver or reduction7Other4Total794 Education and training The Commissioner’s Office gives public office holders comprehensive education and training on the Act’s conflict of interest rules and other requirements. It delivers flexible and accessible educational opportunities for public office holders and the staff who support them through live online and in-person training, targeted outreach, and interactive learning tools. It continually updates its outreach strategies, and refines content based on emerging trends. Offering live online training to all newly appointed public office holders is a key feature of its educational approach. In 2024-2025, the Commissioner’s Office gave 14 of these educational sessions and about 16% of new public office holders participated. It also organizes targeted educational sessions for groups of public office holders and their support staff. Some of these are regularly scheduled sessions on popular topics. In 2024-2025, for example, to respond to an increase in questions about post-employment, it offered six educational sessions on post-employment, attended by almost 400 people. Others are in response to requests for presentations. In 2024-2025, the Commissioner’s Office gave eight presentations to audiences that included ministers’ offices, deputy ministers, Crown corporations, honorary consuls, and corporate governance practitioners within the federal government. Together, they reached almost 300 individuals. To help appointed officials understand the rules, it is developing online training on the Act that should be ready in the new fiscal year. The Commissioner’s Office issues educational documents called “information notices” to help public office holders understand specific aspects of the Act. In 2024-2025, it revised several information notices to reflect changes of practice: Post-employment rules and offers of outside employment (March 2025) – Updated to reflect a change to the way the term “entity” is defined in the Act’s post-employment rules. During a cooling-off period of one or two years after they leave office, reporting public office holders may not contract with or work for an entity they had direct and significant official dealings with during their last year in office. The Commissioner’s Office now excludes from the definition of “entity” not only federal government entities (like departments, agencies and Crown corporations) but also federal parliamentary entities (including the Senate and House of Commons). Reporting public office holders who want to work for a federal government entity or a federal parliamentary entity no longer have to seek an exemption, reduction or waiver of their cooling-off period. While still in office, reporting public office holders must tell the Commissioner about any firm offers of outside employment they receive. The Commissioner’s Office no longer requires them to disclose offers of employment from a federal government entity or a federal parliamentary entity. Reimbursement of costs for divesting controlled assets and withdrawing from activities (February 2025) – Updated to reflect a change to how reporting public office holders who put controlled assets in a blind trust may apply to get paid back for its administrative costs. Before, they had to pay for any professional services before asking for reimbursement. The Commissioner’s Office no longer requires proof of payment. Now, it only needs a copy of the invoice to issue a reimbursement order. Political activities (February 2025) – Updated to better explain how ministers, parliamentary secretaries and ministerial staff can follow the Act while taking part in political activities both during and outside an election period. Post-employment Around the end of their term, the Commissioner’s Office gives public office holders information about the Act’s post-employment rules. Former public office holders are welcome to ask it for advice on how to follow those rules. The Act’s general post-employment rules apply to all public office holders for life. They are not allowed to: Take improper advantage of their previous public office.“Switch sides” on a specific proceeding, transaction, negotiation or case to which the Crown (the federal government) is a party—that is, work for or represent a person or organization on that matter after they acted for or advised the Crown on it.Advise a client, business associate or employer using insider information (information they got while in office and that is not available to the public). Former reporting public office holders must also follow some extra rules during a cooling-off period (two years for former ministers and one year for former parliamentary secretaries). Reporting public office holders may ask the Commissioner to waive or reduce their cooling-off period. If the Commissioner decides to grant a waiver or reduction, the decision and the reasons for it will be posted in the public registry. Under section 37 of the Act, former reporting public office holders must report to the Commissioner certain communications and meetings arranged with certain federal officials. They must also report any meetings they arrange between those officials and any other person. Reporting on conflicts of interest A third key objective of the Commissioner’s Office is to examine and report on allegations of conflict of interest that involve federal public officials. The Commissioner investigates public office holders when he has reasonable grounds to believe that they may have contravened the Conflict of Interest Act, and reports publicly on those investigations. The Commissioner can start an investigation (called an examination) under the Act in one of two ways: When he is asked to investigate by a Senator or a Member of the House of Commons. They must provide reasonable grounds to believe that someone has contravened the Act. The Commissioner’s Office received five examination requests from Members in 2024-2025.On his own initiative if he has reason to believe, based on information from various sources, that someone may have contravened the Act. If the Commissioner stops an examination that he started at the request of a Senator or Member, he must write a report (called a discontinuance report) explaining why. If he stops an examination that he started on his own initiative, he does not have to write a report. When the Commissioner finishes an examination, he issues a public report. He issued three examination reports in 2024-2025. Bloom Report In the Bloom Report (January 15, 2025), the Commissioner found that Mr. Glen Bloom, a former member of the Canadian Cultural Property Export Review Board, did not contravene the Act’s post-employment rules. It was alleged that Mr. Bloom had “switched sides” after leaving public office by representing an art auction house in a 2024 Review Board proceeding that appeared to be about the same issue as a 2022 Review Board proceeding in which he had participated as a Review Board member. Under subsection 34(1) of the Act, former public office holders are not allowed to work for or represent a person or organization on a specific proceeding, transaction, negotiation or case to which the Crown is a party if they previously acted for or advised the Crown on it. The Commissioner found that Mr. Bloom did not contravene subsection 34(1), because the two proceedings dealt with separate reviewable decisions—even though they involved the same art auction house and the same work of art. One proceeding, in 2022, was a procedural determination about whether the Review Board could legally extend a filing deadline. The art auction house had asked the Review Board to review the Canada Border Services Agency’s refusal to grant it an export permit, but missed the deadline to file its request. Mr. Bloom was a member of the panel that concluded the Review Board did not have the authority to extend the deadline. The requested review did not take place. The other proceeding, in 2024, was a review of the merits of the Canada Border Services Agency’s second refusal to give the art auction house an export permit. Mr. Bloom, who was no longer a member of the Review Board, represented the art auction house in this proceeding. Verschuren Report In the Verschuren Report (July 24, 2024), the Commissioner found that Ms. Annette Verschuren, while she was Chairperson of Sustainable Development Technology Canada (SDTC), failed to comply with subsection 6(1) and section 21 of the Act. He found she did not contravene section 9. Under subsection 6(1), public office holders are not allowed to make a decision or participate in decision-making related to the exercise of an official power, duty or function if they know or reasonably should know that, in doing so, they would be in a conflict of interest. Under section 21, they must recuse themselves from any discussion, decision, debate or vote on any matter in respect of which they would be in a conflict of interest. A recusal is more than simply abstaining from a vote. Public office holders must leave the room (physical or virtual). Section 9 prohibits public office holders from using their position as public office holders to seek to influence a decision of another person to further their private interests or those of their relatives or friends, or to improperly further another person’s private interests. Finding one: After Ms. Verschuren was appointed to SDTC in June 2019, she continued to serve on the boards of the Verschuren Centre for Sustainability in Energy and the Environment, which she founded, and the MaRS Discovery District. With respect to most funding decisions involving projects nominated by the Verschuren Centre or MaRS, Ms. Verschuren declared a potential conflict to SDTC’s Board of Directors, and abstained from voting on the decisions. On four occasions, it appears she did not abstain from decisions that benefitted companies nominated by or associated with the two organizations. While she mostly abstained, she did not recuse herself in any of these cases. Finding two: Throughout her tenure, Ms. Verschuren remained Chair, CEO, and majority shareholder of NRStor Inc., a company she founded. The Commissioner found that she failed to comply with subsection 6(1) and section 21 of the Act when she participated in SDTC’s March 2020 and March 2021 decisions to give COVID-19 emergency relief payments to all companies, including NRStor, that had previously been approved for funding. While the original payments to NRStor were approved before she became Chairperson of SDTC, she followed incorrect advice and did not recuse herself from those two subsequent decisions. Finding three: The Commissioner found that Ms. Verschuren did not use her position as Chairperson of SDTC to try to influence other Board members in those two decisions when she moved the motions for the payments. Doing so was simply a formality of her role as Chairperson. Ouimet Report In the Ouimet Report (July 24, 2024), the Commissioner dismissed allegations that Mr. Guy Ouimet, a former director of Sustainable Development Technology Canada (SDTC), contravened the Act. It was alleged that Mr. Ouimet contravened subsection 6(1) and section 21 of the Act by participating in SDTC’s March 2020 and March 2021 decisions to give COVID-19 emergency relief payments to various companies, including Lithion Recycling Inc. At the time of the March 2020 decision, Mr. Ouimet held an option to purchase 1% of Lithion founders’ shares at a cost of $1,250. At the time of the March 2021 decision, he had exercised his option. The Commissioner determined that his financial interest in Lithion in relation to SDTC’s funding decisions was a private interest for the purposes of the Act, and that he participated in both COVID-19 emergency relief funding decisions. However, the Commissioner also applied the principle of de minimis non curat praetor, which is reflected elsewhere in the Act. It is the idea that courts and decision makers are not concerned with trivial things. As Mr. Ouimet’s interest in Lithion was so insignificant, there was no risk of conflict of interest. Review of matters involving a minister In 2024-2025, the Commissioner’s Office reviewed several matters involving the business activities of Minister Randy Boissonnault, although it did not conduct an examination. In spring 2024, prompted by media reports about Minister Boissonnault’s business activities, including his ties with 2050877 Alberta Ltd. (Navis Group) and Global Health Imports Corporation (GHI), a Member of the House of Commons asked the Commissioner to investigate. The Commissioner determined that the request did not meet the requirements of section 44 of the Act because it did not set out reasonable grounds for the belief that the Act had been contravened. In June, the Commissioner appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics. He confirmed to the Committee that, based on the information Minister Boissonnault had voluntarily disclosed to the Commissioner’s Office, it appeared he had complied with the requirements of the Conflict of Interest Code for Members of the House of Commons and the Act on matters involving his companies, and there was no need to investigate. The Commissioner also said he would look into a matter raised in a news report published on the day of his appearance. The article included text messages that Stephen Anderson, who had co-founded GHI with Minister Boissonnault, forwarded to a GHI client on September 8, 2022. They appeared to have been sent by someone called “Randy” who was demanding “a partner call” with Mr. Anderson. When appearing before the House of Commons Standing Committee on Public Accounts in August, the Commissioner said that after reviewing the information Minister Boissonnault had given him about all of his communications on September 8, he concluded there could have been no contact between him and Mr. Anderson. He also told the Committee that after becoming aware of reports of further emails, he had the day before asked Mr. Boissonnault for the same information for September 6 and 7. When he received that, he said, he would determine if there were reasonable grounds to believe that Minister Boissonnault was involved in GHI’s business activities and launch an investigation, if warranted. In September, the Commissioner informed Minister Boissonnault by letter that he considered the matter closed. He made this determination based on the information provided by Minister Boissonnault, and in the absence of any evidence giving him a reason to believe he may have been operating or managing GHI in contravention of paragraph 15(1)(b) of the Act. In keeping with the Act’s confidentiality requirements, the Commissioner’s Office did not make this letter public. However, Minister Boissonnault chose to share it with the media. Penalties There are no penalties when the Commissioner finds in an investigation that someone has contravened the Act. However, examination reports are provided to the Prime Minister and made public on the website of the Commissioner’s Office and in the public registry. This supports transparency and accountability. These reports are also educational tools that can help prevent future conflicts of interest. Public office holders sometimes fail to meet the Act’s requirements in other ways. Non-compliance is rarely deliberate, and the involvement of the Commissioner’s Office usually solves the issue. If it does not, there are some mechanisms it can use to encourage compliance. The Commissioner can impose administrative monetary penalties of up to $500 for not for submitting information on time. In 2024-2025, the Commissioner issued 14 penalties. They are posted in the public registry.​ Administrative monetary penalties Ten $200 penalties paid for failing to disclose a material change relating to assets.Four $200 penalties paid for failing to submit a Confidential Report within 60 days of appointment The Commissioner may order a public office holder to take any measure to comply with the Act. Compliance orders cover things like submitting documents for an annual review, divesting (getting rid of) controlled assets, or quitting prohibited activities. In 2024-2025, the Commissioner issued four compliance orders. All compliance orders are posted in the public registry. Referrals from the Public Sector Integrity Commissioner The Public Sector Integrity Commissioner may refer matters to the Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act. Under section 68 of the Conflict of Interest Act, the Commissioner must issue a public report on each referral, whether he does an investigation or not. The Commissioner did not report on any referrals from the Public Sector Integrity Commissioner in 2024-2025. Case files The Commissioner’s Office sometimes receives information alleging that someone may have contravened the Conflict of Interest Act. The information might come from a Senator or Member of the House of Commons, media reports, or complaints from members of the public. When it gets such information, it may open a case file. Then it does an initial review to determine if there are reasonable grounds to believe a public office holder has contravened the Act. Some of these reviews may lead to examinations. When the Commissioner finds an examination is not warranted, the case file is closed. Total case files: 16 Ongoing: 1Closed without an examination: 12Closed with publication of report: 3 Breakdown of case files Subject of each case file Current or former minister and parliamentary secretary 8 Current or former public office holder 8 Person not subject to the Act 0 Source of these case files Member of the House of Commons 5 Office of the Public Sector Integrity Commissioner 0 Media 2 Member of the general public 7 Within the Office 2 Nature of the concern* Furthering a private interest (subsection 6(1) of the Act) 4 Duty to recuse (section 21) 3 Post-employment rules (sections 33 to 35) 4 Influence (section 9) 7 Preferential treatment (section 7) 2 Private air travel (section 12) 0 Prohibited activities (section 15) 3 Public declaration (section 25) 2 Insider information (section 8) 0 Gifts and other advantages (section 11) 1 Material changes (section 22) 1 *A case file can have more than one concern Managing the Commissioner's Office A team of 51 employees supports the Commissioner. They are experts who specialize in areas like compliance, law, communications, corporate management, investigations, and parliamentary relations. Under the Commissioner’s leadership, employees handle the daily tasks of administering the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. They make sure the processes and structures are in place to support their administration. They also work on other important files like compliance with the Employment Equity Act and the Accessible Canada Act. In September 2024, the Commissioner’s Office released its Pay Equity Plan. In December, it released its 2024 Accessibility Progress Report. The Commissioner provides overall direction and makes the decisions that need his input and approval. He works closely with other members of the Office’s Senior Management Committee. Conflict of Interest and Ethics Commissioner's Office Hon. Konrad W. von Finckenstein, C.M., K.C., Commissioner Advisory and Compliance Lyne Robinson-Dalpé,Director Investigations and Legal Services Martine Richard,Senior General Counsel Communications, Outreach and Planning Melanie Rushworth,Director Corporate Management Sandy Tremblay,Director The Commissioner’s Office devoted a lot of resources to two major projects in 2024-2025. It partnered with House of Commons Digital Services to build a new website. The site supports one of the focus areas identified in its 2025-2030 Strategic Plan: making sure everyone has a user-friendly experience when they interact with the Commissioner’s Office. Drawing on user surveys and testing, it was designed with the needs of users in mind. It will feature a simple structure that will be easy to navigate, and plain-language content. It will also be mobile-friendly. Special sections for Members of the House of Commons, ministers and parliamentary secretaries, reporting public office holders, and public office holders will help these users quickly and easily find information about all the rules that apply to them. The site will also address the information needs of journalists, ethics practitioners, the academic community, and members of the public. The Commissioner’s Office expects it to launch in 2025-2026. The other major project was a move to new workspace. Having previously reduced its footprint from two floors to one, the Commissioner’s Office now occupies space that was purpose-built to better meet operational needs and accessibility requirements. The new workspace is the first of its kind among parliamentary entities. It features larger and more flexible meeting spaces, some with sound masking technology. It incorporates new technologies that can accommodate evolving work styles and allows more employees to work collaboratively on-site. All perimeter doors and inside amenities are fully accessible. The Commissioner’s Office partnered on this project with the House of Commons Administrative Services, the Sergeant-at-Arms, the Parliamentary Protective Service, and Public Services and Procurement Canada. To make sure it has the right positions and the right people in them to support its mandate, the Commissioner’s Office ran five staffing processes in 2024-2025. No employees left. The Office’s financial statements are audited each year by an independent external auditor. Its financial information for 2024-2025 is outlined in Appendix A. Legal developments The Commissioner’s decisions on investigations are sometimes challenged in court. Dealing with these cases can help clarify the Commissioner’s mandate and powers. One court case was underway in 2024-2025. Democracy Watch had asked the Federal Court of Appeal to review former Commissioner Mario Dion’s findings in the 2021 Trudeau III Report. He had concluded that Prime Minister Justin Trudeau did not contravene the Conflict of Interest Act when the government chose WE Charity to run a COVID-19 program, even though some of his family members were closely involved in some of WE Charity’s projects. The Commissioner determined that the Act only covers real or potential conflicts of interest, and a situation that simply appears to give rise to an appearance of conflict does not contravene the rules. In the Notice of Application for Judicial Review it submitted to the Court, Democracy Watch pointed out errors it believes the Commissioner made in both law and fact. It argued that the Commissioner was wrong to conclude that the Act’s definition of conflict of interest excludes the appearance of conflict, and that he was wrong about Mr. Trudeau not being friends with WE Charity’s cofounders. Responding on the Commissioner’s behalf, the Attorney General of Canada objected to that request because section 66 of the Act does not allow the types of grounds for review that Democracy Watch raised. In a motion to strike the Notice of Application, the Attorney General wrote that section 66 does not allow the Court to review the alleged errors of law and fact. It limits judicial review to questions of jurisdiction, procedural fairness, and fraud or perjured evidence. The judge who heard that motion decided that the full panel of the Court hearing the merits of Democracy Watch’s application should examine the question about section 66, so it could clarify the important issue of how privative clauses should be interpreted and applied (Democracy Watch v. Canada [Attorney General], 2022 FCA 208). The Federal Court of Appeal heard the matter on March 24, 2024. On October 2, 2024, the Federal Court of Appeal dismissed Democracy Watch’s application for judicial review. In its reasons for judgment, it wrote that the Act reflects Parliament’s intention to give both Parliament and the Court distinct supervisory roles in monitoring potential conflict of interests involving public office holders. In that context, the Court said, it makes sense to insulate from review by the Court the determinations made by the Commissioner within his jurisdiction. The Commissioner is an independent Officer of the House of Commons whose position is within the legislative branch of government. Section 86 of the Parliament of Canada Act makes it clear that he acts under the direction of the House of Commons when enforcing the Conflict of Interest Code for Members of the House of Commons. The Court interpreted section 66 in this context. It wrote that it is very clear from the Act’s requirement for the Commissioner to give his reports to the Prime Minister, that it is up to the Prime Minister to decide what to do with the Commissioner’s findings, and to the House of Commons to hold the government to account. The sanction, it said, is meant to be political, not judicial. This conclusion is reinforced by the fact that the Commissioner’s reports are made public, and that their conclusions do not determine what actions should be taken. The Court was therefore of the view that cases cited by Democracy Watch do not apply to this application for judicial review. Those cases were about decisions made by quasi-judicial or administrative tribunals, and not about findings by an Officer of Parliament. It wrote that the Conflict of Interest Act provides for dual parliamentary and judicial oversight, with an elaborate procedure to regulate ethical conduct through political consequences. In the context of such a scheme, where accountability is intended to lie primarily with the legislative branch, courts should clearly exercise judicial restraint and adhere to the limits prescribed by section 66 of the Act in their judicial review function. In December 2024, Democracy Watch filed an application for leave to appeal to the Supreme Court of Canada. (Leave was granted on May 1, 2025.) Appendix A: Financial resources summary (thousands of dollars) Program Activity 2023-2024 2024-2025 Alignment to Governmentof Canada OutcomesActual Spending Main Estimates Total Authorities Actual Spending Administration of the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons 6,8757,7087,7087,594Government AffairsContributions to employee benefit plans839867939939 Total spending7,7148,5768,6478,533 Plus: cost of services received without charge1,017N/AN/A918 Net cost of department8,7318,5768,6479,451 The budget process for the Commissioner’s Office is outlined in the Parliament of Canada Act. Each year, the Office estimates how much money it will need for the next fiscal year. The Speaker of the House of Commons reviews this estimate and sends it to the President of the Treasury Board, who presents it to the House along with the Main Estimates (the Government of Canada’s budget) for that fiscal year. The Standing Committee on Access to Information, Privacy and Ethics reviews and reports on the Office’s effectiveness, management and operations, and its spending plans. The figures in this summary have not been audited. Complete audited financial statements will be posted on the Office’s website. Appendix B: Proposed legislative amendments This is the text of proposed amendments to the Parliament of Canada Act and the Conflict of Interest Act that the Commissioner has identified. Underlining indicates text that would be added or changed. SECTION 82—TENURE PARLIAMENT OF CANADA ACT 82 (3) In the event of the absence or incapacity of the Commissioner, or if that office is vacant, and where no interim commissioner has been appointed under subsection (2), the Commissioner of Lobbying of Canada may exercise all the powers of a commissioner appointed under subsection 81(1). 82 (3) En cas d’absence ou d’empêchement du commissaire ou de vacance de son poste, et lorsqu’aucun commissaire par intérim n’a été nommé en vertu du paragraphe (2), le commissaire au lobbying du Canada peut exercer tous les pouvoirs d’un commissaire nommé en vertu du paragraphe 81(1). SECTION 4—CONFLICT OF INTEREST CONFLICT OF INTEREST ACT 4 (1) For the purposes of this Act, a public office holder is in a conflict of interest when he or she exercises an official power duty or function that provides an opportunity to further his or her private interests or those of his or her relatives or friends or to improperly further another person’s private interests. (2) For the purposes of this Act, a public office holder is in an apparent conflict of interest if there is a reasonable perception, which a reasonably well-informed person could properly have, that the public office holder’s ability to exercise an official power or perform an official duty or function must have been affected by the public office holder’s private interest or the private interest of his or her relatives or friends. 4 (1) Pour l’application de la présente loi, un titulaire de charge publique se trouve en situation de conflit d’intérêts lorsqu’il exerce un pouvoir officiel ou une fonction officielle qui lui fournit la possibilité de favoriser son intérêt personnel ou celui d’un parent ou d’un ami ou de favoriser de façon irrégulière celui de toute autre personne. (2) Pour l’application de la présente loi, un titulaire de charge publique se trouve en situation de conflit d’intérêts apparent lorsqu’il y a de la part d’une personne raisonnablement bien informée, une crainte raisonnable que la capacité d’exercer un pouvoir officiel ou une fonction officielle doit avoir été affectée par son intérêt personnel ou par celui d’un parent ou d’un ami. SECTION 5—GENERAL DUTY CONFLICT OF INTEREST ACT 5. Every public office holder shall arrange his or her private affairs in a manner that will prevent the public office holder from being in a conflict of interest or an apparent conflict of interest. 5. Le titulaire de charge publique est tenu de gérer ses affaires personnelles de manière à éviter de se trouver en situation de conflit d’intérêts ou en conflit d’intérêts apparent. SECTION 20—DEFINITIONS CONFLICT OF INTEREST ACT 20.1 The Governor in Council on the recommendation of the Commissioner may, by order, designate any asset or class of assets as an exempt asset under the Act that, in the opinion of the Commissioner, does not constitute any risk of a conflict of interest. 20.1 Le gouverneur en conseil sur recommandation du commissaire peut, par décret, désigner tout bien ou toute catégorie de biens comme étant un bien exclu au sens de la loi qui, de l’avis du commissaire, ne pose aucun risque de conflit d’intérêts. SECTION 2—DEFINITIONS CONFLICT OF INTEREST ACT private interest does not include an interest in a decision or matter (a) that is of general application; (b) that affects a public office holder or his or her relatives or friends as one of a broad class of persons; or (c) that concerns the remuneration or benefits received by virtue of being a public office holder. intérêt personnel N’est pas visé l’intérêt dans une décision ou une affaire : a) de portée générale; b) touchant le titulaire de charge publique ou un parent ou un ami faisant partie d’une vaste catégorie de personnes; c) touchant la rémunération ou les avantages sociaux d’un titulaire de charge publique. SECTION 15—PROHIBITED ACTIVITIES CONFLICT OF INTEREST ACT Prohibited activities 15 (1) No reporting public office holder shall, except as required in the exercise of his or her official powers, duties and functions, (a) engage in employment or the practice of a profession; (b) manage or operate a business or commercial activity; (c) continue as, or become, a director or officer in a corporation or an organization; (d) hold office in a union or professional association; (e) serve as a paid consultant; or (f) be an active partner in a partnership. Activités interdites 15 (1) À moins que ses fonctions officielles ne l’exigent, il est interdit à tout titulaire de charge publique principal : a) d’occuper un emploi ou d’exercer une profession; b) d’administrer ou d’exploiter une entreprise ou une activité commerciale; c) d’occuper ou d’accepter un poste d’administrateur ou de dirigeant dans une société ou un organisme; d) d’occuper un poste dans un syndicat ou une association professionnelle; e) d’agir comme consultant rémunéré; f) d’être un associé actif dans une société de personnes. Exception (1.1) Despite paragraph (1)(a), for the purpose of maintaining his or her employment opportunities or ability to practice his or her profession on leaving public office, a reporting public office holder may engage in employment or the practice of a profession in order to retain any licensing or professional qualifications or standards of technical proficiency necessary for that purpose if (g) the reporting public office holder does not receive any remuneration; and (h) the Commissioner is of the opinion that it is not incompatible with the reporting public office holder’s duties as a public office holder. Exception (1.1) Malgré l’alinéa (1)a), afin de préserver ses perspectives d’emploi ou sa capacité d’exercer sa profession une fois qu’il a cessé d’occuper sa charge, le titulaire de charge publique principal peut occuper un emploi ou exercer une profession dans le but de conserver un permis d’exercice, une qualification professionnelle ou un certain niveau de compétence technique qui lui est nécessaire à cette fin si, à la fois : g) il ne reçoit aucune rémunération; h) le commissaire estime que cela n’est pas incompatible avec sa charge publique. Exception (2) Despite paragraph (1)(c), a reporting public office holder who is a director or officer in a Crown corporation as defined in section 83 of the Financial Administration Act may continue as, or become, a director or officer in a financial or commercial corporation but only if the Commissioner is of the opinion that it is not incompatible with his or her public duties as a public office holder. Exception : titulaire de charge publique principal (2) Malgré l’alinéa (1)c), le titulaire de charge publique principal qui occupe un poste d’administrateur ou de dirigeant dans une société d’État au sens de l’article 83 de la Loi sur la gestion des finances publiques peut occuper ou accepter un poste d’administrateur ou de dirigeant dans une société commerciale ou financière si le commissaire estime que ce poste n’est pas incompatible avec sa charge publique. Exception (3) Despite paragraph (1)(c), a reporting public office holder may continue as, or become, a director or officer in an organization of a philanthropic, charitable or non-commercial character but only if the Commissioner is of the opinion that it is not incompatible with his or her public duties as a public office holder. (3.1) Despite paragraphs (1)(b), (d), (e) and (f), a reporting public office holder may engage in any of those activities if the Commissioner is of the opinion that they are not incompatible with his or her public duties as a public office holder. Autre exception (3) Malgré l’alinéa (1)c), le titulaire de charge publique principal peut occuper ou accepter un poste d’administrateur ou de dirigeant dans un organisme philanthropique, caritatif ou à but non lucratif si le commissaire estime que ce poste n’est pas incompatible avec sa charge publique. (3.1) Malgré les alinéas (1)b), d), e) et f), le titulaire de charge publique principal peut exercer une des activités qui y sont visées si le commissaire estime que l’activité n’est pas incompatible avec sa charge publique. Political activities (4) Nothing in this section prohibits or restricts the political activities of a reporting public office holder. Activités politiques (4) Le présent article n’a pas pour effet d’interdire ou de restreindre les activités politiques d’un titulaire de charge publique principal. SECTION 52—VIOLATION CONFLICT OF INTEREST ACT Violation 52 Every public office holder who contravenes one of the following provisions commits a violation and is liable to an administrative monetary penalty not exceeding $3,000: (i) subsections 22(1), (2) and (5); (j) section 23; (k) subsections 24(1) and (2); (l) subsections 25(1) to (6); (m) subsections 26(1) and (2); and (n) subsection 27(7). Violations 52 Le titulaire de charge publique qui contrevient à l’une des dispositions ci-après de la présente loi commet une violation pour laquelle il s’expose à une pénalité d’au plus 3 000 $ : i) les paragraphes 22(1), (2) et (5); j) l’article 23; k) les paragraphes 24(1) et (2); l) les paragraphes 25(1) à (6); m) les paragraphes 26(1) et (2); n) le paragraphe 27(7).

This report summarizes the Office’s work in administering the Conflict of Interest Code for Members of the House of Commons. That work includes compliance activities, education and outreach initiatives, and investigations. Commissioner's message I am pleased to report on the administration of the Conflict of Interest Code for Members of the House of Commons in 2024-2025. This was my first full fiscal year as part of my seven-year mandate as Commissioner. The activities reported here reflect the approach taken by the Commissioner’s Office in the last year. That approach focuses on our mandate, and it supports three key objectives. One, foster public confidence that the actions of elected and appointed federal officials are free from conflicts of interest. Two, help public officials manage their conflicts of interest so the most competent and qualified people can move in and out of public service without any problems. Three, examine and report on allegations of conflicts of interest that involve elected or appointed federal officials. The Commissioner’s Office uses various tools to achieve these objectives, including one-on-one interface with each elected or appointed official, training and educational resources, and our website. The Conflict of Interest Code for Members of the House of Commons strikes a balance between confidentiality, to protect Members’ privacy, and maximum transparency, to support accountability. We apply both these concepts in our work. Confidentiality ensures Members can freely and openly share their issues with us. Transparency allows us to be as open as possible with Parliament and the public about everything the Commissioner’s Office does. Everyone should understand what we are doing and why we are doing it. This helps ensure the credibility of the Code and its administration. The Commissioner’s Office is committed to being efficient and making decisions quickly. When there are allegations of wrongdoing, quick resolutions are essential as reputations may be at stake. Building on the work of the previous year and the principles identified above, we have developed a five-year strategic plan. We look forward to implementing this approach in the upcoming years and meeting new challenges. Vision, mission and mandate Vision To safeguard public confidence in the integrity of Parliament and government institutions. Mission To help elected and appointed public officials avoid conflicts of interest. Mandate Administer the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act so as to manage conflicts of interest. The Commissioner’s Office has identified four priorities in its 2025-2030 Strategic Plan to advance its vision, mission, and mandate: Avoiding conflicts of interest Improve processes and resources to help public officials manage conflicts of interests efficiently, while supporting transparency and accountability. User-friendly experience Ensure every interaction with public officials is positive, seamless and user-focused, engendering trust and satisfaction. Healthy and fulfilling workplace Foster a healthy, inclusive work environment where employees always act with integrity. Support diversity, professional development, and hybrid work. Tools, knowledge, and skills Give employees modern tools and training so they have the knowledge and skills to effectively carry out the mandate of the Commissioner’s Office. Fostering public confidence A key objective of the Commissioner’s Office is to help Canadians trust that the actions of elected and appointed public officials at the federal level are free from conflicts of interest. Canadians must feel confident that those officials do not use their public office for private gain. The things they do in their jobs should be to benefit the public, not themselves or someone they know. Competing interests must not interfere with their ability to be fair and objective. Everything the Commissioner’s Office does—from advising public officials to reporting to Parliament—ultimately aims to foster this public confidence. This report highlights how it works to build public trust in the activities of elected Members of Parliament. They are subject to the Conflict of Interest Code for Members of the House of Commons. Members who are ministers or parliamentary secretaries are also subject to the Conflict of Interest Act. Snapshot of Members of the House of Commons on March 31, 2025 0 Members Note: When Parliament is dissolved for a general election, incumbents are no longer considered Members for the purposes of the Code, and parliamentary secretaries lose their positions. Source: Quarterly statistical reports, Commissioner’s Office Confidentiality and transparency The two complementary concepts of keeping things private and being open are key to the work of the Commissioner’s Office. Confidentiality encourages public officials to communicate freely and openly with the Commissioner’s Office, and to ask it for advice when faced with a situation that may put them in a conflict of interest. When public officials disclose information to the Commissioner’s Office, other than statutorily protected information, most of it is kept confidential. The Office uses this information to help them arrange their affairs to avoid conflicts of interest, and to make sure they are following the rules. The Conflict of Interest Code for Members of the House of Commons has strict confidentiality requirements. These allow Members to fully disclose their situation so the Commissioner can give them advice based on complete information. All their interactions with the Commissioner’s Office are confidential and can only be made public by the Members themselves, not by the Office. Transparency is a keystone for fostering public confidence. One of the Code’s stated purposes is to show the public that Members are held to standards that place the public interest ahead of their private interests, and to provide a transparent system so the public can see this happening. Transparency is built into the Code through its public declaration requirements. Some of the information that Members disclose to the Commissioner’s Office must be posted in a public registry for anyone to see. The public registry is a searchable database that can be accessed through the Office’s website. It contains all the information about public officials that the Commissioner is allowed to make public.  Public registry activitiesPostingsViews2024-20251,316170,628Five-year average1,261101,438 The public registry contains information on sitting Members. Their information stays in it until they leave elected office. When a federal election is called, incumbents are no longer considered Members for the purposes of the Code, so the Commissioner’s Office removes their information under the Code from the registry. The Commissioner’s Office is transparent about its own activities. It publishes quarterly statistical reports that contain data on what it is doing and how it is meeting its service standards. Reporting to Parliament The Commissioner has a duty to report to Parliament, testify before parliamentary committees, and answer questions from Parliament. As an independent Officer of the House of Commons, he reports to Parliament directly, not through a minister. By March 31 each year, the Commissioner is required to send a list of sponsored travel under the Code to the Speaker of the House of Commons for tabling. Under subsection 15(1) of the Code, sponsored travel is any travel worth more than $200 that is not fully paid by the government, a political party, a recognized parliamentary association, or by Members themselves. The Commissioner could not send the List of Sponsored Travel 2024 by March 31, because the House of Commons was not in session. Parliament was prorogued in January then dissolved in March for a general election. By June 30 each year, the Commissioner sends a report on the administration of the Conflict of Interest Code for Members of the House of Commons to the Speaker of the House of Commons for tabling. The Commissioner reports on inquiries (investigations) under the Code to the House of Commons. The Commissioner did not issue any inquiry reports in 2024-2025. The Commissioner’s Office sends communiqués to parliamentarians about its reports and other activities. It sent four of these in 2024-2025. Committee oversight The House of Commons Standing Committee on Procedure and House Affairs is responsible for the Code. The Commissioner needs the Committee’s approval for guidelines or forms related to the Code. If the Committee approves any such documents, it reports them to the House. The Commissioner’s Office can only use them if the House agrees with the Committee’s report. The House of Commons Standing Committee on Access to Information, Privacy and Ethics has oversight responsibility for the Commissioner’s Office. The Committee reviews its annual spending estimates, and matters related to the Commissioner’s reports under the Conflict of Interest Act. Committee appearances in 2024-2025 DateDescriptionApril 16, 2024 House of Commons Standing Committee on Access to Information Privacy and Ethics, Main Estimates 2024-2025 Commissioner Konrad von Finckenstein appeared with Sandy Tremblay, Director, Corporate Management Melanie Rushworth, Director, Communications, Outreach and Planning​ June 4, 2024 House of Commons Standing Committee on Access to Information Privacy and Ethics, Compliance of a Minister with the Conflict of Interest Act Commissioner Konrad von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance August 8, 2024 Standing Committee on Public Accounts Report 1, ArriveCAN of the 2024 Reports of the Auditor General of Canada Commissioner Konrad von Finckenstein appeared with Michael Aquilino, Legal Counsel September 16, 2024 Standing Committee on Industry and Technology Recent Investigation and Reports on Sustainable Development Technology Canada Commissioner Konrad von Finckenstein appeared with Michael Aquilino, Legal Counsel September 17, 2024 Standing Senate Committee on National Finance Main Estimates 2024-2025 Commissioner Konrad von Finckenstein appeared September 16, 2024 House of Commons Standing Committee on Procedure and House Affairs Forms and Procedural and Interpretative Guidelines from the Conflict of Interest and Ethics Commissioner (in camera meeting) Commissioner Konrad von Finckenstein appeared with Lyne Robinson-Dalpé, Director, Advisory and Compliance October 21, 2024 House of Commons Standing Committee on Public Accounts Report 6, Sustainable Development Technology Canada, of the 2024 Reports 5 to 7 of the Auditor General of Canada Commissioner Konrad von Finckenstein appeared with Michael Aquilino, Legal Counsel Public communications In support of transparency, the Commissioner’s Office communicates as openly with the public as it is allowed to under the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. It shares as much information as it can, and in different ways. For example, it posts information on its website. Website usage2024-2025Users127,500Page views280,000 This year, the website attracted twice as many users and had twice as many page views as the year before. Website traffic rose in the last two quarters. The Commissioner’s Office designed and built a new website so different users can quickly and easily find the information they are looking for. The content is written in plain language to make it more accessible. The website will be launched in 2025-2026. The Commissioner’s Office uses social media to share information about its activities and updates from the public registry that may be of interest to journalists, academics, Canadian and international ethics practitioners, and others. Social media usageX @EthicsCanada @ÉthiqueCanada LinkedIn @ethics-ethique-canada Posts7980Followers4,3571,052 It responds to journalists and members of the public who want information by telling them as much as possible about how the Code and the Act work, and directing them to the public registry when appropriate. Media inquiries in 2024-2025Public inquiries in 2024-2025 114 emails and and phone calls from members of the media Over 85% were question​s about a specific elected or appointed official, or the status of a current case fileAbout 10% were general inquiries about the Office’s role and mandate5% were about the Commissioner’s investigation reports 400 emails and phone calls from members of the public 80% did not fall within the Commissioner’s mandate and were redirected20% were general inquiries about the role of the Office or complaints about a particular official. Some were shared with the Investigations division for follow-up The Commissioner’s Office also gives presentations about its work to interested audiences that in 2024-2025 included: Dalhousie University, Ethics in Action course Carleton University, Ethics in Political Management course Many Facets of Parliament, a seminar for parliamentary employeesMontreal Integrity Network, a network of professionals who help organizations develop ethics and compliance programs Connecting with others The Commissioner’s Office works with other organizations to stay updated on and share best practices. This collaboration supports its objective of fostering public confidence that elected and appointed officials’ actions are free from conflicts of interests. It continues to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN) of federal, provincial, and territorial conflict of interest commissioners. In September 2024, the Commissioner, a Legal Counsel and the Director of Communications, Outreach and Planning attended CCOIN’s annual meeting, hosted by Ethics Commissioner Ariane Mignolet in Quebec City. The Commissioner’s Office is a member of the Ethics Practitioners Association of Canada (EPAC). With members from government, business, voluntary sector, and the academic community, EPAC promotes ethical practices in organizations, and supports ethics practitioners across Canada. The Commissioner’s Office is an active member of two international ethics organizations. The Réseau francophone d’éthique et de déontologie parlementaires (RFEDP) promotes exchanges between parliaments and entities in the Organisation internationale de la Francophonie [link in French only] that are interested in ethics and codes of conduct. RFEDP activities in 2024-2025: The Commissioner, the Director of Advisory and Compliance, and the Director of Communications, Outreach and Planning participated in its 2024 Annual General Meeting, held in Brussels. As a member of the RFEDP’s Bureau, the Director of Advisory and Compliance participated in a May 2024 seminar in French Polynesia as a speaker and moderator. It was part of an ongoing RFEDP project to train parliamentarians in the Francophonie on avoiding conflicts of interest. In July, she attended a meeting of the Bureau in Montreal, while participating in bilateral discussions and committee meetings during the annual meeting of the Assemblée parlementaire de la Francophonie [link in French only]. The Council on Governmental Ethics Laws (COGEL) is a U.S.-based organization of government ethics practitioners.  COGEL activities in 2024-2025: Office representatives attended COGEL’s 2024 conference, held in Los Angeles, in December 2024, and joined several virtual events during the year.  Other international outreach activities: In May 2024, the Commissioner’s Office gave input to Global Affairs Canada for its response to a questionnaire on the G20 Anti-Corruption Working Group Accountability Report. In March 2025, an Office representative attended the 2025 OECD Global Anti-Corruption and Integrity Forum (hosted by the Organisation for Economic Co-operation and Development). Helping elected officials manage conflicts of interest Another key objective of the Commissioner’s Office is to help Members manage their conflicts of interest so the most competent and qualified people can move in and out of public service without any problems. Like all experienced people, these individuals may face conflicts between public and private interests. The Commissioner’s Office helps them avoid and manage such conflicts by giving them information about the Code’s rules. It also guides them on how to follow those rules and submit required information. In October 2024, the Commissioner’s Office conducted a confidential and anonymous survey of Members. It is using the results to guide how it communicates and engages with them. By comparing the results with those of a similar survey it ran in 2022, it can measure progress in meeting Members’ needs. The Commissioner’s Office shared the main findings of the 2024 survey with all Members. Personal advice The Commissioner’s Office helps Members follow the rules that apply to them, by giving them information and advice when they need it, and by answering their questions promptly. It assigns each Member an advisor who works with them throughout their time in office. Their advisor helps them understand and follow the rules and meet the Code’s reporting requirements. Members can ask their advisor for advice at any time. The Commissioner’s Office reaches out to all Members soon after they are elected or re-elected. It aims to contact each Member personally within three days after notice of their election or re-election appears in the Canada Gazette. To make sure the advice it gives Members is consistent, the Commissioner’s Office tracks the topics they ask about, so it can identify training needs and spot trends that might impact its workload.  When asked, the Office explains the Code’s requirements to candidates running for election to the House of Commons. Breakdown of advice by topic2024-2025Gifts and other benefits99Letters of support and fundraising50Material changes259General obligations159Total567 Guidance on reporting requirements To achieve and maintain compliance with the Code’s disclosure provisions, Members must meet various reporting requirements. This means giving the Commissioner’s Office detailed personal and financial information about themselves and their family members. The Commissioner’s Office keeps most of that information private, and only uses it to determine what Members need to do to ensure they are following the rules. As required by the Code’s public declaration provisions, the Commissioner’s Office makes some of it public, by posting in the public registry. This supports transparency and accountability. Advisors walk new and re-elected Members through the initial compliance process under the Code. This process is an opportunity for them to familiarize themselves with the rules and address potential issues. Step 1: Each Member must give the Commissioner’s Office detailed personal and financial information about themselves and their family, by filling out a Disclosure Statement within 60 days after their election is confirmed. Step 2: Their advisor reviews this information and helps them organize their affairs to avoid conflicts of interest. Step 3: The advisor prepares a summary of the information in the Disclosure Statement. The Member then has 60 days to review, sign and return this Disclosure Summary. Step 4: The Commissioner’s Office posts the Disclosure Summary in the public registry, and the initial compliance process is over. The Commissioner’s Office helps Members meet other reporting requirements during their whole time in elected office. They must tell it about the following things, within certain deadlines. Some of this information is made public. Material changes (any changes to the information in their Disclosure Statement). Gifts or other advantages worth $200 or more that they or their family members accept. They must publicly declare multiple gifts received from one source in a 12-month period with a total value of $200 or more. Sponsored travel. Any travel worth more than $200 that is not fully paid by the government, a political party, a recognized parliamentary association, or by the Members. Abstentions. If present when a matter in which they have a private interest is being debated or voted on in the House of Commons or by a committee they are part of, Members must disclose the general nature of the interest to the Clerk of the House of Commons. The Clerk will send the disclosure to the Commissioner, who will post it in the public registry. If they have a private interest that could be affected by their parliamentary work in other situations, they must inform the party concerned about the general nature of the interest, and send a written notice about it to the Commissioner, who will post it in the registry. Public declarations by Members in 2024-20252024-2025Disclosure summaries327Gifts and other benefits39Material changes64Sponsored travel20Private interest1Total451 Members must also complete an annual review. Each year, they must file a new Disclosure Statement with the Commissioner’s Office, which contacts them to launch the review process. In 2024-2025, 180 annual reviews were completed. Education and training The Commissioner’s Office gives Members education and training on the Code’s conflict of interest rules and other requirements. To help them understand and retain important information, it gives them the same information more than once, and in different ways. In the summer of 2024, the Commissioner’s Office launched an online course on the Code, through the House of Commons intranet site. The course is bilingual, accessible, mobile-friendly, and easy to use. It features interactive scenarios that give Members practical learning experiences. This course was developed in response to a March 2023 amendment to section 32 of the Code, which made training on it mandatory for all Members. The Commissioner is now required to offer individualized training that includes educational scenarios, and Members must complete it within 120 days after their election is confirmed. While Members’ staff are not subject to the Code, they can play an important role in helping Members meet its requirements and are encouraged to complete the course. Under subsection 26(4) of the Code, the Commissioner occasionally issues educational documents called “advisory opinions” to help Members understand how the Code applies in specific situations. No advisory opinions were issued in 2024-2025. Screengrab of the online course for Members Reporting on conflicts of interest A third key objective of the Commissioner’s Office is to examine and report on allegations of conflict of interest that involve federal public officials. The Commissioner investigates Members when he has reasonable grounds to believe that they may have contravened the Conflict of Interest Code for Members of the House of Commons, and reports publicly on those investigations. The Commissioner can start an investigation (called an inquiry) under the Code in one of three ways: When asked to investigate by a Member of the House of Commons who has reasonable grounds to believe that another Member has contravened the Code. When directed to by the House of Commons. On his own initiative if the Commissioner has reasonable grounds to believe, based on information from various sources, that a Member may have contravened the Code. There are no penalties when the Commissioner finds in an inquiry that a Member has contravened the Code. He may recommend appropriate sanctions, but it is up to the House of Commons to impose any sanctions. Inquiry reports are made public on the website of the Commissioner’s Office, and in the public registry. They are educational tools that can help prevent future conflicts of interest. They also support transparency and accountability. The Commissioner did not issue any inquiry reports in 2024-2025. Case files The Commissioner’s Office sometimes receives information alleging that a Member may have contravened the Code. The information might come from another Member, media reports, complaints from members of the public or other sources. When it gets such information, it may open a case file and conduct an initial review. Some of these reviews may lead to inquiries. When the Commissioner finds an inquiry is not warranted, the case file is closed. Total case files: 0 Ongoing: 0Closed without an inquiry: 3Closed with publication of report: 0 Breakdown of case files Subject of each case file Current or former Member of the House of Commons 3 Person not subject to the Code 0 Source of these case files Member of the House of Commons 0 Media 0 Member of the general public 3 Within the Office 0 Nature of the concern Furthering a private interest (section 8 of the Code) 3 Using influence (section 9) 0 Required disclosure of information (sections 20 to 24) 0 Attempting to engage in prohibited activities (section 11) 0 Sponsored travel (section 15) 0 Gifts and other advantages (section 14) 0 Managing the Commissioner's Office A team of 51 employees supports the Commissioner. They are experts who specialize in areas like compliance, law, communications, corporate management, investigations, and parliamentary relations. Under the Commissioner’s leadership, employees handle the daily tasks of administering the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. They make sure the processes and structures are in place to support their administration. They also work on other important files like compliance with the Employment Equity Act  and the Accessible Canada Act. In September 2024, the Commissioner’s Office released its Pay Equity Plan. In December, it released its 2024 Accessibility Progress Report. The Commissioner provides overall direction, and makes the decisions that need his input and approval. He works closely with other members of the Office’s Senior Management Committee. Conflict of Interest and Ethics Commissioner's Office Hon. Konrad W. von Finckenstein, C.M., K.C.,Commissioner Advisory and Compliance Lyne Robinson-Dalpé,Director Investigations and Legal Services Martine Richard,Senior General Counsel Communications, Outreach and Planning Melanie Rushworth,Director Corporate Management Sandy Tremblay,Director The Commissioner’s Office devoted a lot of resources to two major projects in 2024-2025. It partnered with House of Commons Digital Services to build a new website. The site supports one of the focus areas identified in its 2025-2030 Strategic Plan: making sure everyone has a user-friendly experience when they interact with the Commissioner’s Office. Drawing on user surveys and testing, it was designed with the needs of users in mind. It will feature a simple structure that will be easy to navigate, and plain-language content. It will also be mobile-friendly. Special sections for Members of the House of Commons, ministers and parliamentary secretaries, reporting public office holders, and public office holders will help these users quickly and easily find information about all the rules that apply to them. The site will also address the information needs of journalists, ethics practitioners, the academic community, and members of the public. The Commissioner’s Office expects it to launch in 2025-2026. The other major project was a move to a new workspace. Having previously reduced its footprint from two floors to one, the Commissioner’s Office now occupies space that was purpose-built to better meet operational needs and accessibility requirements. The new workspace is the first of its kind among parliamentary entities. It features larger and more flexible meeting spaces, some with sound masking technology. It incorporates new technologies that can accommodate evolving work styles and allows more employees to work collaboratively on-site. All perimeter doors and inside amenities are fully accessible. The Commissioner’s Office partnered on this project with the House of Commons Administrative Services, the Sergeant-at-Arms, the Parliamentary Protective Service, and Public Services and Procurement Canada. To make sure it has the right positions and the right people in them to support its mandate, the Commissioner’s Office ran five staffing processes in 2024-2025. No employees left.  The Office’s financial statements are audited each year by an independent external auditor. Its financial information for 2024-2025 is outlined in the Appendix. Appendix: Financial resources summary (thousands of dollars) Program Activity 2023-2024 2024-2025Alignment to Governmentof Canada OutcomesActual Spending Main Estimates Total Authorities Actual Spending Administration of the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons 6,8757,7087,7087,594Government AffairsContributions to employee benefit plans839867939939 Total spending7,7148,5768,6478,533 Plus: cost of services received without charge1,017N/AN/A918 Net cost of department8,7318,5768,6479,451 The budget process for the Commissioner's Office is outlined in the Parliament of Canada Act. Each year, the Office estimates how much money it will need for the next fiscal year. The Speaker of the House of Commons reviews this estimate and sends it to the President of the Treasury Board, who presents it to the House along with the Main Estimates (the Government of Canada's budget) for that fiscal year. The Standing Committee on Access to Information, Privacy and Ethics reviews and reports on the Office’s effectiveness, management and operations, and its spending plans. The figures in this summary have not been audited. Complete audited financial statements will be posted on the Office's website.

Our purpose and values Purpose Vision To safeguard public confidence in the integrity of Parliament and government institutions. Mission To help elected and appointed public officials avoid conflicts of interest. Mandate Administer the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act so as to manage conflicts of interest. Values Respect for people We foster inclusion, civility and dignity in our interactions with colleagues and stakeholders. Professionalism We are diligent and consistent, while maintaining a spirit of collaboration that is strengthened by the diversity of people and ideas. Integrity We build and maintain trust by upholding the highest ethical standards and demonstrating responsible stewardship. Impartiality We provide independent, objective and non-partisan direction and advice, while remaining open to a diversity of views. Building a roadmap for 2025-2030 This strategic plan serves as a formal roadmap, outlining long-term goals and the actions necessary to achieve them. It provides a clear framework to align our resources and efforts with our mission: to help elected and appointed public officials (“regulatees”) avoid conflicts of interest. By following this plan, we aim to transform challenges into opportunities and drive meaningful progress for the Office. What do we want to achieve in the next five years? The Office’s main objective is to provide clear guidance, education, and effective enforcement in a timely manner. The process of complying with the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons must be modernized, simple and efficient. Specifically, the Office must provide tailored, proactive guidance to help regulatees navigate complex situations and remain in compliance during their time in office and while moving in and out of public office. In the next five years, the Office must work towards the following three goals: Embrace innovation: The Office must adopt and leverage new technologies to enhance efficiency and productivity in its work. It must develop innovative tools and resources to improve awareness and compliance.Remain neutral: The Office must respond to evolving legislative and political contexts to stay relevant, safeguard its impartiality, and help the public understand and trust its role and effectiveness.Preserve expertise: In the next five years, there is anticipated turnover in the Office’s senior positions. The Office must retain corporate memory and invest in developing talent and expertise. How will the strategic plan help to achieve these goals? The Plan establishes four focus areas, enabling the Office to purposefully create and implement supporting projects and initiatives. 1 – Avoiding conflicts of interest Enhance and streamline our processes, strategies, and resources to ensure that regulatees can efficiently and effectively manage their conflicts of interest, while supporting transparency and accountability. 2 – User-friendly experience Ensure that every interaction—whether through the website, the portal or employees—provides a positive, seamless, and user-centred experience, fostering trust, understanding, and satisfaction for all regulatees. 3 – Healthy and fulfilling workplace Foster a healthy, inclusive, and fulfilling work environment where employees consistently act with and embody integrity in their actions. Promote a workplace culture that supports diversity, hybrid work, and professional development. 4 – Tools, knowledge and skills Provide employees with reliable, modern tools, and appropriate training to equip them with the knowledge and skills needed to effectively fulfill the Office’s mandate. Objectives and expected results of each focus area 1 – Avoiding conflicts of interest Enhance and streamline our processes, strategies, and resources to ensure that regulatees can efficiently and effectively manage their conflicts of interest, while supporting transparency and accountability. Objectives Streamline compliance processes: Simplify initial compliance processes, annual review processes, disclosures, declarations and the set-up of compliance measures.Enhance transparency and accountability: Communicate clearly and accessibly about the regimes the Office administers.Provide clear and consistent advice: Ensure that all Office interactions offer aligned guidance.Tailor training and education: Offer customized training for regulatees during onboarding, throughout their term in office and after they leave office.Increase public engagement: Develop educational and parliamentary outreach programs to build understanding and clarify the Office’s role and mandate.Publish user-friendly products: Create accessible materials that explain investigation reports as well as changes to and interpretations of the Act and the Code, and manage them through efficient and streamlined processes.Ensure compliance: Help regulatees remain compliant during their mandate and as they move in and out of office. Expected results Consistency and clarity: Demonstrate consistent application of the rules.Prevention focus: Centre compliance processes and education on preventing conflicts of interest.Election readiness: Be prepared to support regulatees throughout and after the election process. We will measure our progress by comparing the results of the public office holder and Member surveys and internal file audits. The Office will keep track of processes that are streamlined, making note of the timeline to complete tasks, modifications, changes to delegation of authority to complete them, and the use and updates of the Internal Practice Manual. 2 – User-friendly experience Ensure that every interaction—whether through the website, the portal or employees—provides a positive, seamless and user-centred experience, fostering trust, understanding, and satisfaction for all regulatees. Objectives Offer a reliable portal: Provide fast and straightforward transactions.Maintain a user-friendly website: Ensure that information is easily accessible and user-focused.Promote transparency: Integrate a searchable public registry.Support positive user experiences: Ensure that regulatees have positive interactions with the Office. Expected results Successful information submissions: Regulatees successfully submit comprehensive information with minimal technical issues and increasing self-sufficiency with subsequent use.Accessible information: Regulatees and the general public can find, and make use of, general information on the website.Prioritized needs: Advisory and compliance processes will prioritize the needs of regulatees. We will measure our progress by comparing the results of the public office holder and Member surveys. The Office will track the status of the tools that were implemented (advisory and compliance portal, modernized and integrated website and public registry, etc.) and feedback from internal and external users. 3 – Healthy and fulfilling workplace Foster a healthy, inclusive and fulfilling work environment where employees consistently act with and embody integrity in their actions. Promote a workplace culture that supports diversity, hybrid work, and professional development. Objectives Engage and motivate the workforce: Foster an engaged and motivated workforce.Promote inclusivity and equity: Implement inclusive and equitable practices across the Office.Support bilingualism: Respect and support bilingualism.Minimize security risks: Strengthen measures to minimize security risks.Facilitate knowledge transfers: Establish processes for proactive knowledge transfers and structured onboarding.Ensure effective communications: Maintain timely and effective internal communications.Identify and mitigate stressors: Develop mechanisms to identify and mitigate common stressors such as workload, file complexity, deadlines, and service standards.Update and reinforce standards: Update and reinforce the Code of Values and Standards of Conduct. Expected results Follow the Office’s Code of Values: Put the Code of Values into practice both inside and outside the Office.Achieve a successful hybrid workplace: The Office will maintain a successful hybrid workplace.Respond to workforce challenges: The Office will anticipate and mitigate workforce challenges. We will measure our progress by comparing the results of employee satisfaction surveys, participation rates for professional development and retention levels. Human resources practices will include periodic reviews of hiring practices and workplace demographics. IT and Security will conduct audits, incident reporting and annual employee training to measure and ensure effectiveness and understanding of security requirements. Feedback through formal and informal channels will be used to understand internal communications, stress and workload, and learning and adoption success with Office tools, among other things. The Office will conduct pulse surveys as well. 4 – Tools, knowledge and skills Provide employees with reliable, modern tools and appropriate training to equip them with the knowledge and skills needed to effectively fulfill the Office’s mandate. Objectives Ensure a user-friendly client management system: Support Office employees with a user-friendly client management system.Prioritize coherent information management practices: Implement coherent information management practices that are designed for employees to follow with guidelines.Monitor and analyze trends: Track and analyze trends that may affect the work of the Office.Facilitate expertise sharing: Promote formal and purposeful sharing of expertise, including soft skills, within the Office and through active participation in external knowledge groups.Provide comprehensive training: Offer ongoing employee training on systems and tools.Standardize collaboration tools: Standardize the use of collaboration tools and publish an Office-approved list (OneNote, Loop, Teams chat, etc.).Enhance onboarding process: Streamline, formalize and enhance the onboarding process for new employees and managers.Encourage shadowing and collaboration: Promote employee shadowing, collaboration and mentoring. Expected results Support the Office’s mandate: Ensure that all tools, systems and initiatives directly support the Office’s mandate and reduce purely administrative tasks required in compliance processes.Anticipate challenges: The Office will monitor and anticipate internal and external challenges.Provide formal training: Employees will receive formal rounds of training on new processes and tools. We will track our progress and continually improve by monitoring key indicators. This includes analyzing results from employee satisfaction surveys, tracking the number of formal training sessions organized, and calculating the percentage of employees who complete both mandatory and optional training. Additionally, we will conduct adoption surveys or establish metrics to assess the use and effectiveness of the tools and processes provided to employees. Monitoring progress and measuring results Progress on the plan will be reported to the Senior Management Committee every quarter and shared with the Office on the intranet. Projects and initiatives will be added to the leads’ performance agreements to ensure that their workload adequately reflects these new initiatives. Focus area How will we measure success? Avoiding conflicts of interest The processes, strategies and resources that help elected and appointed public officials manage their conflicts of interest are efficient. Minimal number of references to the rules not being applied equally in the public office holder and Member surveys. Website analytics. User-friendly experience The user has a positive experience in each interaction with the Office (website, portal, advisor). Minimal number of references to the tools not being user-friendly in the public office holder and Member surveys. Website analytics. Healthy and fulfilling workplace The Office promotes a healthy, inclusive and fulfilling work environment where employees always act with integrity. Employee feedback is positive (employee satisfaction surveys, pulse surveys, minimal number of negative comments in the suggestion box). Tools, knowledge and skills Employees are equipped with reliable and modern tools, insights and skills to help fulfill the Office’s mandate. Thorough research is undertaken to leverage the benefits of artificial intelligence (AI) and other technologies, employees are trained on these tools and given guidance on their safe and effective use. Employee feedback is positive (employee satisfaction surveys, pulse surveys). Additional research What challenges do we face? Directors, managers and employees helped to identify internal challenges as well as challenges in the outside environment. Pressing internal challenges Workload The increasing volume and complexity of requests for advice from regulatees, along with the rising number of reporting public office holders over the past five years, add significant complexity to compliance and enforcement. Internal tools Completion of and transition to a new client management system are necessary, in addition to planning for updates. Information management Improvements to information accessibility are needed, ensuring consistent corporate records, especially for elected and appointed public officials’ files. Safety and security Complete a Threat and Risk Assessment and update policies accordingly. Website renewal Office surveys with regulatees, as well as informal public feedback, demonstrate that the website is not providing the help needed and requires a structure that allows key audiences to navigate to the information they want. Envisioned updates include a more interactive and plain language search or chatbot feature to help guide users. Adapting to hybrid workplace Continue operating in a hybrid model while moving to a new floor, which requires transition planning. Plain language The Office is adapting most of its products to incorporate plain language. It will need to continue to develop its practices to ensure that plain language is being used adequately where necessary. Employee expertise and tools In recent years, case files and requests for advice have become more complex, especially when regulatees have multiple controlled assets and holdings. The Office must ensure that advisors have the tools necessary to manage these complex files effectively. The Office needs to develop internal processes and systems that make information easier to find, analyze and digest, while maintaining robust security protocols. The Office must identify the expertise necessary to integrate AI and generative AI tools responsibly. These technologies offer opportunities across the Office, but they must be integrated in ways that support innovation and collaboration without hindering progress, while being mindful of risks of bias and overreliance. It is important to properly train employees on these tools and provide guidance on their safe and effective use. Challenges identified during the 2024 public office holder survey and the 2024 Members survey A small number of respondents indicated that there were inconsistencies in the advice provided and level of experience among advisors.There is an opportunity to improve procedural guidance related to certain matters.There is a perception that the Office tends to focus on small administrative issues, not on the big issues that affect trust in government.There is growing interest in in-person meetings.There is an opportunity to use more plain language in products.The Office’s current disclosure forms are not seen as user-friendly. Political challenges Changing political landscape Changes to the political landscape directly affect the Office’s workload. General elections lead to turnover, may shift the parliamentary dynamics, typically mean increased movement from the public sector to the private sector, and result in changes to Governor-in-Council (GIC) appointments. The composition of Members of Parliament changes (younger, more tech-savvy, interested in hybrid work, etc.), and this is also reflected in GIC appointments in some areas. Erosion of trust in Parliament Trust in Canadian institutions and Parliament has declined (Transparency International’s Corruption Perception Index, 2025 Edelman Trust Barometer, Organisation for Economic Co-operation and Development (OECD) survey, etc.). Scandals related to conflicts of interest and ethics breaches receive media and public scrutiny. These scandals were discussed at length by parliamentary committees. The Commissioner was invited on numerous occasions to appear before committees to discuss these issues and provide a better understanding of the role of the Office. Values and ethics are a salient topic Integrity in public institutions is a strong prevention tool for corruption. The Treasury Board Secretariat and the Privy Council Office are looking to update their values and ethics tools. Ethics commissioners across Canada have published investigation reports that have received national attention. The Office must be prepared to apply new advances internally. Open government There is a push towards increased transparency from government. The Office must monitor and advance its open government policies, ensuring that they do not conflict with confidentiality rules related to regulatees. Economic challenges Increased scrutiny on public spending and procurement Recent procurement processes and funding decisions have received intense media and public scrutiny. Public spending has become a common topic during question period and in the media. This rising scrutiny related to government expenses may translate into greater oversight of the Office’s budget and expenditures. This may require creative solutions to reduce budget spending. Questions about finding efficiencies among various organizations through administrative mergers may be raised during parliamentary appearances. Legislative changes could further alter jurisdictions, and increase workloads and the complexity of functions. Inflation and federal deficit Affordability and the federal deficit are top of mind for Canadians and for regulatees. Programming choices related to budget reductions have been discussed and are being implemented in the core public administration. The Office will need to adapt to this new environment. Shared economy and cryptocurrencies The ever-shifting economic landscape affects the definitions of assets in the Act and the Code. Social challenges Adapting to a hybrid workplace In 2025, the Office will move to a new, modernized workspace reflective of a planned hybrid workplace. This will require adjustments in employee engagement, collaboration, and productivity management, coupled with updated policies and practices to ensure a smooth transition. Office turnover and demographics Office demographics are shifting (turnover shift of 4% in the past five years, 23% of employees and managers will meet retirement eligibility in the next five years, new generation is joining the workforce). Implementing ethics in the workplace There is an emphasis on creating a strong integrity structure within public institutions. (The Treasury Board, OECD, Council on Governmental Ethics Laws and Réseau francophone d'éthique et de déontologie parlementaires are focusing on ways to measure and enhance public integrity.) The Office must determine which new practices it should apply to maintain a solid framework for integrity. Respecting bilingualism The Office is acquiring a number of new tools and technologies. While employees must be able to work in the official language of their choice, the Office must also deliver its services in the language of choice of regulatees and other interested parties. Prioritizing accessibility, diversity and inclusion The federal government and Parliament are continuing to advance accessible and inclusive procedures and policies. The Office’s statistics for employment equity designated groups are in line with the representation within the federal public service (women (77%), members of a visible minority (18%), persons with a disability (18%), Indigenous people (5%)). Technological challenges Automation and artificial intelligence The Treasury Board Secretariat is further developing policies and directives on automated decision making and the use of AI. This is a field that will likely reshape current policies and procedures. This is an opportunity for the Office to automate certain processes (workflow automation, transcription and drafting tools, summarizing tools, media monitoring). Security threats and cyberattacks New cybersecurity challenges that result in security breaches require the Office to be well equipped to handle these new threats. The Office must also increase its expertise on the numerous ways that AI can be used to access confidential information. Misinformation and disinformation The rise of disinformation increases the need to be the source for credible information related to the role and functions of the Office. The Office must also increase its expertise on the numerous ways that AI can be used to share false information. Legal challenges Conflicts of interest on the spectrum of corruption Preventing conflicts of interest is strongly linked to the prevention of corruption. This link is widely discussed by international counterparts. Although the Canadian legal system separates the two, the Office can still gather best practices related to the fight against corruption. Foreign interference legislation New legislation on foreign interference may have an impact on the Office’s work by introducing enhanced scrutiny or additional requirements for appointed public officials, as well as potential changes to the Office’s scope of responsibilities. Five-year trends Bolded quarters indicate that a general election took place (October 2019 and September 2021) Bolded quarters indicate that a general election took place (October 2019 and September 2021) Preliminary implementation plan A preliminary list of projects and initiatives has been identified by focus area to ensure progress towards the strategic plan’s objectives. For each initiative, a designated lead will be assigned, along with a clear timeline and a budget to establish accountability. A more detailed implementation plan will be developed collaboratively with each lead to outline specific steps and success measures. Progress will be reported quarterly, providing transparency and an opportunity to assess outcomes. The plan will also be refreshed annually to enable informed discussions on timelines, scope, adjustments, shifts in direction, or the removal of initiatives that no longer align with the Office’s priorities or goals. This process ensures continuous alignment, accountability and adaptability. Focus area Project/Activity/Initiative Avoiding conflicts of interest Tailored formats for training and development for Members and public office holders Avoiding conflicts of interest Expanded training and education focus to ensure that regulatees understand the rules and address all conflicts of interest User-friendly experience Creating an Office-wide process to implement changes to interpretation of the Act/Code. Understanding the impacts of interpretation changes and adapting implementation. User-friendly experience Improving transparency and adherence to “open governance” User-friendly experience Streamlined compliance processes: minimum clicks and manual work for users User-friendly experience A user-friendly website that allows the user to find information quickly User-friendly experience A new functional client management tool and portal that requires minimal time and effort from the user. The tool should also provide a robust information management structure to help streamline compliance processes. User-friendly experience Digital training tools are made available to the Office’s key audiences Healthy and fulfilling workplace Updating internal human resources policies Healthy and fulfilling workplace Staffing continuity plan for the Office Healthy and fulfilling workplace Preparing for the retirement of key management employees Healthy and fulfilling workplace Threat and risk analysis is conducted Healthy and fulfilling workplace Equity, diversity and inclusion are prioritized Healthy and fulfilling workplace Accessibility Plan is implemented Tools, knowledge and skills Harnessing collaboration tools for the hybrid world Tools, knowledge and skills Data analytics and monitoring are improved and shared across the Office Tools, knowledge and skills Improving information management practices Tools, knowledge and skills Surveys of Members and public office holders are conducted approximately every two years, and the results are used to monitor progress Tools, knowledge and skills Formal and specialized training and development opportunities are identified for the Office Tools, knowledge and skills Research into past Members’ questions about lobbying and conflict of interest regimes being merged

The table below summarizes all the public reports the Commissioner’s Office has released on investigations under the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. It lets you sort them by when they were released, the person the Commissioner investigated, what claims led to the investigation, and what rules the Commissioner considered. You can also see at a glance if those rules were broken. WIDGET-1

The Conflict of Interest and Ethics Commissioner’s duties in applying the Conflict of Interest Act for public office holders and the Conflict of Interest Code for Members of the House of Commons include investigating alleged contraventions of these regimes. This page seeks to give participants in an investigation (called “examinations” under the Act and “inquiries” under the Code) an idea of what to expect. It focuses on practices common to examinations under the Act and inquiries under the Code, noting differences where relevant. Nature of investigations The primary purpose of examinations and inquiries conducted by the Office of the Conflict of Interest and Ethics Commissioner is to determine the relevant facts surrounding an alleged breach of the Act or the Code to permit the Commissioner to draw conclusions and make appropriate observations or recommendations. These investigations are not like proceedings before a court or tribunal because the Commissioner does not preside over a dispute between two adverse parties. The Commissioner’s investigations involve gathering and analyzing the relevant information to make findings of fact and conclusions. Under the Code, the Commissioner is expressly mandated to make recommendations. Under the Act, the Commissioner can require witnesses to provide written or oral evidence, under oath, and to produce documents. The Code explicitly requires Members of the House of Commons to cooperate with respect to an inquiry, whether they are the subject of the inquiry or are called as witnesses. Confidentiality Examinations and inquiries are conducted in private. The Commissioner and Office employees maintain the confidentiality of information collected during an investigation except as necessary to carry out the investigation or to establish the grounds for the analysis and conclusions in a report. Subjects and witnesses are asked to keep information confidential. They have a responsibility to help maintain the confidentiality of investigations by not discussing the content of any interviews or written correspondence with anyone other than their counsel, if applicable. The Commissioner will not normally comment on an investigation. Under the Code, the Commissioner is prohibited from making any comments in relation to any preliminary review or inquiry except to confirm that a review has been completed or to describe the reasons for not proceeding with an inquiry where the matter to which the inquiry relates has already been made public. Information for subjects The subjects of investigations under the Act or the Code are assured of certain rights. As neither the Act nor the Code sets out the procedure for conducting investigations, the Commissioner has adopted a process that balances confidentiality obligations, the integrity of the investigation process, and procedural fairness. Both the Act and the Code contain provisions that require the Commissioner to give the subject a reasonable opportunity to make representations during the investigation. The subjects of investigations are permitted to have a lawyer or may choose to be assisted or represented by a person of their choice. Process When an investigation is initiated, the Commissioner writes to the subject to explain the examination process and sets out the details of the alleged contraventions, providing a copy of the written request for an investigation, if applicable. Under the Code, a preliminary review is required as a first step to determine if an inquiry is warranted. Subjects and witnesses may be asked to provide documentary evidence, to present themselves at an interview or to respond to questions by telephone or in writing. Those being interviewed will be asked to swear an oath. Interviews are recorded and transcripts are made of the proceedings. The Commissioner generally has two interviews with the subject: one at the outset of the investigation, and the second at the end of the fact-finding process. The subject has the right to make representations to the Commissioner, personally or through counsel, at any time during the investigation process. Finally, the portions of the report that set out the facts determined by the Commissioner are provided to the subject and their counsel, if applicable, for review before the report is finalized. They may make representations to the Commissioner, and those recommendations are taken into consideration before the report is finalized. Information for counsel Investigations under the Act and the Code are substantially different from the adversarial processes associated with conventional civil or criminal litigation. The investigation process does not involve hearings, but fact-finding interviews with the subject of the investigation and witnesses. The Office of the Conflict of Interest and Ethics Commissioner is responsible for gathering some of the information required to make the factual determinations that will underpin the Commissioner’s analysis and conclusions. The Commissioner does not make findings of civil or criminal liability, but gathers information to determine the relevant facts in order to make appropriate conclusions as to whether the person who is the subject of the investigation has breached the Act or the Code. The Commissioner’s reports are made public. Under the Code, the Commissioner is expressly mandated to make recommendations in the final reports. The Office considers that the role of counsel is to assist their clients in presenting their views and to assist the Commissioner in obtaining all the relevant facts in an expeditious manner. Counsel may accompany their clients to their own interview(s), but counsel does not have the right to be present during the interviews of other witnesses or to cross-examine them. In order to protect the integrity of the fact-gathering process, counsel representing the subject of an investigation may not also represent a witness in the same investigation. Counsel may make representations during their client’s interview(s) or in writing during the investigation process.

The Commissioner does not have the power to impose penalties if he finds in an investigation that someone has contravened the Conflict of Interest Code for Members of the House of Commons or the Conflict of Interest Act. However, reports on investigations (called inquiries under the Code and examinations under the Act​) are made public. They shed light on elected and appointed officials’ conduct, and can also educate other federal officials to help prevent future rule breaking. In the case of an examination report under the Act, the Prime Minister decides whether to take any further action as a result of the report’s findings. The only penalties in the Act are administrative monetary penalties, but these do not apply in examinations. They are for reporting public office holders who fail to meet certain reporting deadlines in the Act.​ When the Commissioner finds in an inquiry that a Member of the House of Commons has contravened the Code, he may recommend appropriate sanctions. It is up to the House of Commons to impose any sanctions. There are no penalties in the Code.

Public office holder surveys

If you are a parliamentarian… Senators and Members of the House of Commons who have reasonable grounds to believe someone has contravened the Conflict of Interest Act may ask the Commissioner to investigate. Members of the House of Commons who have reasonable grounds to believe another Member has contravened the Conflict of Interest Code for Members of the House of Commons may ask the Commissioner to investigate. You can ask the Commissioner to investigate someone under the Act by filling out the Examination Request Form for Parliamentarians. You can ask the Commissioner to investigate someone under the Code by filling out the Inquiry Request Form for Parliamentarians. If you are not a parliamentarian… Members of the public who think someone may have contravened the Act or the Code are welcome to submit information for the Commissioner to consider. (He may also consider information from the public that a Senator or Member of the House of Commons brings to his attention.) You can fill out the Investigation Request Form for Members of the Public. All investigations are done in private. The Commissioner’s Office does not tell members of the public if or how it is following up on complaints they have made.