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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.

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.

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 my report on the performance of the Commissioner’s duties and functions under the Conflict of Interest Code for Members of the House of Commons in relation to public office holders for the fiscal year ending March 31, 2024, 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, Honourable Konrad W. von Finckenstein, C.M., K.C.Conflict of Interest and Ethics Commissioner 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 2023-2024. The Commissioner’s Office administers the Code and the Conflict of Interest Act to manage conflicts of interest and safeguard public trust. It does that by helping elected and appointed public officials avoid conflicts of interest. Ultimately, the goal is to safeguard public confidence in the integrity of Parliament and government institutions. The Office has a two-fold purpose. One, to help elected and appointed public officials avoid and manage conflicts of interest, and two, to facilitate the movement of qualified people in and out of public service. Like all experienced and competent people, those individuals will, over time, face potential conflicts of interest. While they are in public office, the Commissioner’s Office helps them avoid and manage such conflicts to protect the public interest. This means giving them credible, consistent, and timely advice. It also means being helpful and innovative, and making it as easy as possible for them to comply with the​ Code. It does not mean just looking for possible contraventions. If there is non-compliance, the Commissioner’s Office works with Members to bring them back into compliance. If there are reasonable grounds to believe there is a conflict of interest, the Office will investigate as needed and issue a public report. The report will expose conflicts, if there are any, to allow the public to consider them at election time. To help the Office run more efficiently, administrative processes were streamlined, and more authority was delegated to members of the Senior Management Committee. The Commissioner is the key decision maker, supported by employees of the Office. Employees must be empowered and equipped so they can work independently and efficiently on things that do not need to cross the Commissioner’s desk. The Office worked to make its communications and outreach activities more effective. It continued using plain language to make its materials easy to understand and accessible. To achieve its mandate and mission, the Office must be as transparent as possible. It must communicate as openly as it can with Parliament and Canadians about what it does and why, and in a way people understand. Our approach is reflected in the Office’s vision, mission, and mandate. They capture the why, what, and how of its activities. I look forward to building on this approach to the role of Commissioner in the years to come. Vision, mission, 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. Activities at a glance The Office helps Members of the House of Commons manage their conflicts of interests to safeguard public trust.​ 1. When they are elected As soon as they are elected, all Members must complete their initial compliance process. The Office helps them complete it after each general election and by-election. There are currently 338 seats in the House of Commons. 2. While they are in office Throughout their mandate, Members ask the Office about gifts, letters of support and fundraising, changes to their circumstances and their general obligations under the Code. On average, the Office receives about 660 requests for advice every year. 3. When they leave Members are no longer considered Members once they leave Office so the Code no longer applies to them. The Office met these service standards over 89% of the time: 3 days to contact new or reappointed Members3 days to help Members when they reach out​ Data is based on a five-year average from April 1, 2019 to March 31, 2024. Members of the House of Commons The Conflict of Interest Code for Members of the House of Commons applies to all 338 elected Members of Parliament. Members who are ministers or parliamentary secretaries are also subject to the Conflict of Interest Act. As tracked in the Office’s quarterly statistical reports​, the number of Members went up and down during the year. Here is a snapshot of Members on March 31, 2024: Members of the House of Commons (336) 39 ministers39 parliamentary secretaries258 Members of the House of Commons who are not ministers or parliamentary secretaries Five by-elections accounted for most of the turnover among Members in 2023-2024.​ Helping Members comply The Conflict of Interest Code for Members of the House of Commons has many rules that Members must learn and follow to avoid conflicts between public and private interests. The Commissioner’s Office guides them on how to follow the rules. It also helps them identify and submit required information. That information helps the Commissioner’s Office spot possible conflicts of interest. To support transparency and prevent conflicts of interest, some of it is made public. The Commissioner’s Office reaches out to all Members soon after they are elected or re-elected. It aims to contact each one personally within three days after notice of their election or re-election appears in the Canada Gazette​. The Office met this service standard 96% of the time in 2023-2024, more than its 80% target. The Commissioner’s Office works with Members regularly during their time in office. Personal guidance It starts by assigning each Member an advisor who can focus on their individual needs. This opens an ongoing dialogue that lasts for as long as they are in Parliament. Their personal advisor helps them understand and follow the rules and meet the Code’s reporting requirements. They also give them advice tailored to their personal situation. Members can ask their advisor for advice and guidance at any time. The Commissioner’s Office also offers training on the Code to all new and returning Members. Since March 2023, training is mandatory under section 32 of the Code. Members must complete it within 120 days after their election is confirmed.​ Initial compliance process Their personal advisor walks newly elected or re-elected Members through the initial compliance process​. This is a critical step that they must complete to achieve compliance with the Code. It is an opportunity for them to learn the rules and address potential issues. Members must give the Commissioner’s Office a lot of personal and financial information, for themselves and their families, by filling out a disclosure statement. Their advisor reviews it and helps them arrange their affairs to avoid conflicts of interest. The advisor then prepares a summary of the information in each Member’s disclosure statement (it is called a “disclosure summary”) for the Member to review and sign. When the Office posts the disclosure summary in the public registry, the initial compliance process is over. This signals that the Member has complied with their initial reporting obligations under the Code. They are now on track to maintain their compliance and avoid conflicts of interest going forward. Ongoing reporting requirements While they are in office, Members must tell the Commissioner’s Office about: Any changes to the information in their disclosure statement. These are called “material changes.”Any gifts or other benefits worth $200 or more that they or a family member accept.Sponsored travel. This is 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.Recusals (when they stepped back from debating or voting on anything in which they have a private interest). Members are not allowed to participate in debates or vote on questions in which they have a private interest. Members must disclose the general nature of any private interest they have in a matter that comes before them. The Code sets out how they must do that. The information is posted in the public registry. Advice The Commissioner’s Office advises Members on issues that may involve potential conflicts of interest. It encourages them to get in touch any time they have questions or concerns. In 2023-2024, the Office received 31% more requests for advice than the five-year average. To make sure the advice the Office gives Members is consistent, it records how the Commissioner interprets the Code in an internal practice manual. It launched a major update of this tool in 2023-2024. The Office also tracks the kinds of things Members ask about, so it can identify training needs, and spot trends that might impact its workload. The Commissioner’s Office aims to respond to Members’ requests for advice within three business days. It met this service standard 93% of the time in 2023-2024, more than its 80% target. 2023-2024 in numbers The Office helps Members understand the rules and arrange their affairs so they can avoid conflicts of interest during their term in office. Helping Members understand the rules under the Conflict of Interest Code for Members of the House of Commons 5 information kits outlining rules and obligations sent to newly elected Members5 initial compliance processes completed Helping Members arrange their affairs to avoid conflicts of interests 231 annual reviews completed 862 instances of advice provided494 public registry postings (includes postings related to initial compliance and ongoing obligations)93 sponsored trips from January 1 to December 31, 2023, totalling $847,828.22 Advice by topic in 2023-2024 Requests for advice from Members of the House of Commons 862 Material changes 396 General obligations 256 Gifts and other benefits 140 Letters of support and fundraising 70 Requests for advice over five years (five-year average: 660) 2019-2020 2020-2021 2021-2022 2022-2023 2023-2024 476490605866862 Public declarations by Members in 2023-2024 Public declarations by topic 494 Disclosure summaries 318 Sponsored travel 77 Material changes 56 Gifts and other benefits 41 Private interest 2 Educating and informing Prevention is a major focus of the Conflict of Interest Code for Members of the House of Commons. Members must learn the rules so they can recognize potential conflicts of interest and take steps to avoid them. The Commissioner’s Office helps them learn what they must—and must not—do to avoid conflicts of interest. Education and training The Commissioner’s Office offers Members education and training on the Code’s conflict of interest rules and its other requirements. To help them understand and retain important information, it gives them the same information more than once, and in different ways. In 2023-2024, it gave presentations to three Members’ offices. It organized two educational sessions for Members’ staff. They are not subject to the Code, but can help Members comply with it. In March 2023, the House of Commons amended section 32 of the Code to make training on the Code mandatory for all Members. It requires the Commissioner to offer individualized mandatory training for Members, including the use of educational scenarios. Members must complete the training within 120 days after their confirmation of election. To implement this requirement, the Office gave one-on-one training to the five new Members elected in 2023-2024. It also developed an online course about the Code. In a fall 2022 survey, it had asked Members about different training methods, and most said they preferred online learning modules. The course is bilingual, accessible, mobile-friendly, and easy to use. It features interactive scenarios that engage learners and give them practical learning experiences. Linked to specific topics, the scenarios encourage active participation and problem-solving. The course will be launched on the House of Commons intranet site in the new fiscal year. In the meantime, the Office provides newly elected Members access to it. Activity framework The Office’s strategic communications and engagement plan is a framework for all these activities. It is aimed at meeting the needs of Members, a primary audience. Actions in the plan are designed to help the Commissioner’s Office give them the information they need promptly, and in the formats they prefer. Addressing non-compliance The Commissioner’s Office upholds the Conflict of Interest Code for Members of the House of Commons’ focus on prevention by helping Members avoid conflicts of interest. It also helps them meet the Code’s other requirements, like disclosing information and arranging their private affairs. Sometimes, however, Members fail to comply with the Code. This can happen for all kinds of reasons, including some that are not in their control. It is rare for someone to deliberately ignore their obligations under the Code, or to refuse to cooperate with the Commissioner’s Office. When a Member does not comply with the Code, their advisor in the Commissioner’s Office works with them to get them back on track. That usually solves the issue. Investigations The Commissioner can investigate possible contraventions of the Code. Investigations (called “inquiries” in the Code) can start in three ways: Any Member who has reasonable grounds to believe another Member has contravened the Code may ask the Commissioner to investigate. The Office then follows a process set out in the Code to decide if an inquiry is warranted.The House of Commons may direct the Commissioner to conduct an inquiry. This has never happened. The Commissioner may decide to investigate if there is reason to believe a Member has contravened the Code. No inquiries were underway as of March 31, 2024. The Commissioner’s Office reports publicly on all inquiries. It did not issue any inquiry reports in 2023-2024. Sanctions The Commissioner cannot impose sanctions under the Code. This is because only the House of Commons has the right to discipline its own members. However, the Commissioner may recommend in inquiry reports that the House impose appropriate sanctions. Case files The Commissioner’s Office sometimes receives information that a Member may have contravened the Code. The information might come from a Member, media reports, complaints from members of the public or other sources. When the Commissioner’s Office gets such information, it may open a case file. Then it does an initial review (called a “preliminary review”). Some of these reviews may lead to inquiries. When the Office finds an inquiry is not warranted, it closes the case file.​ 2023-2024 in numbers Case files (a case file is a concern that is reviewed by the Office) Total case files: 11 Ongoing: 2Closed without an inquiry: 9Closed with publication of report: 0 Breakdown of case files Subject of each case file Current or former Member of the House of Commons 11 Person not subject to the Code 0 ​​​Source of these case files Member of the House of Commons 4 Media 0 Member of the general public 7 Within the Office 0 ​​​Nature of the concern* Furthering a private interest (section 8 of the Code) 5 Using influence (section 9) 3 Required disclosure of information (sections 20 to 24) 4 Attempting to engage in prohibited activities (section 11) 2 Sponsored travel (section 15) 1 Gifts and other advantages (section 14) 1 *A case file can have more than one concern Reporting to Parliament The Conflict of Interest and Ethics Commissioner has a duty to report to Parliament, testify before parliamentary committees, and answer questions from Parliament. The Commissioner, an independent Officer of the House of Commons, reports on behalf of Canadians to Parliament directly, not through a minister. The Commissioner sends reports under the Code to the Speaker of the House of Commons. The Speaker tables them in the House. The Office sends communiqués to parliamentarians about reports and other activities under the Code and the Conflict of Interest Act. It sent three communiqués in 2023-2024. List of sponsored travel The Commissioner sends a list of sponsored travel under the Code by March 31 each year. 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 sent the 2023 List of Sponsored Travel​ on March 26, 2024. The Speaker tabled it in the House on the next sitting day, April 8. The list shows that sponsored travel accepted by Members returned to historical levels in 2023. They accepted 93 sponsored trips—two thirds more than in 2022—with a combined declared value of $847,828.22. On average, Members accepted 83 sponsored trips a year from 2007 to 2019. In the pandemic years of 2020 and 2021, the average was just seven. Annual report By June 30 each year, the Commissioner sends an annual report on the administration of the Conflict of Interest Code for Members of the House of Commons. Inquiry reports The Commissioner reports on inquiries (investigations) under the Code to the House of Commons. The Commissioner did not issue any inquiry reports in 2023-2024. Committee oversight The House of Commons Standing Committee on Procedure and House Affairs is responsible for the Code. It did not invite the Commissioner to appear in 2023-2024. Supporting transparency Transparency is like a window that lets people see how things work. It is a pillar of the Conflict of Interest Code for Members of the House of Commons and, indeed, of all effective conflict of interest regimes. Ultimately, it can promote trust in government decision making. Members must not only follow the rules in the Code, they must be seen to do so. By seeing how things work, Canadians can feel confident that the government is doing what it is supposed to do. To keep them accountable, Parliament and Canadians need access to clear, accurate and up-to-date information. Transparency is built into the Code through its disclosure and public declaration requirements. Members must give the Commissioner information about their financial interests, personal relationships, and other factors that could potentially influence their decision making. Public registry Some of that information is made public. The Code requires the Commissioner’s Office to maintain a public registry. It is a searchable database that contains all the information about individual Members that the Commissioner is allowed to make public. When a Member is no longer a Member, the Commissioner’s Office removes their information from the registry. Once it is gone from the registry, it is no longer available from the Office. When a Parliament is dissolved, triggering a general election, Members are no longer considered Members, so the Commissioner’s Office removes their information from the public registry. After the election, the Office posts information for new and re-elected Members in the registry as they complete the initial compliance process​ under the Code. The Office tracks where each Member is in the initial compliance process under the Code. It publishes that information in a Members’ Compliance Status Report each month. Public communications The Commissioner’s Office also aims for transparency in its public communications. By law, it must keep some information—like any dealings it has with individual Members—private. But it shares as much information as it can, and in a variety of ways. For example, the Office posts information on its website and social media, and responds to media and members of the public who ask for information. The Office uses social media to keep track of conversations about ethics issues. It also shares information about its activities and the public registry on social media. The Office aims its messaging at educating its secondary audiences: media, academics, international and domestic ethics practitioners, and others who are interested in the Office’s activities. It communicates with Members in other ways. When responding to inquiries from media and members of the public, the Office gives as much information as possible about how the Code works. It also includes links to the public registry when appropriate. It only answers emails from members of the public that are directly addressed to it, not ones it is just copied on. The Office is also transparent about its activities. It publishes quarterly statistical reports that show, for example, how many times it responds to Members’ requests for advice, and what it is doing in the area of education. These reports also include figures on how it meets its service standards. The Office aims to respond to media inquiries within four hours, and to inquiries from members of the public within 10 business days, at least 80% of the time. In 2023-2024, it met these service standards 96% of the time for media inquiries, and 91% of the time for public inquiries. 2023-2024 in numbers Public registry Almost 1,300 items posted, in line with the five-year average Over 120,000 public registry page views, up 40% from the year before Website 51,000 new users, up 22% from the year before 200,000 page views, up 35% from the year before About 59% of website traffic resulted from Internet searches. This could mean that people were interested in the work of the Office and decided to access the website that wayThe Office’s emails, social media posts and media advisories drove most of the rest of the users to the website Social media The Office’s X followers grew by 8% to 4,284It tweeted 30% less than in the previous yearIts LinkedIn followers rose from 35 to 599 Public inquiries The Office received over 3,100 emails and phone calls from members of the public Media inquiries The Office received and responded to over 140 media requests, up 23% Almost a third of these requests resulted in an article or social media mention 50% were questions about a specific public office holder or Member of the House of Commons, or the status of a current case file42% were general inquiries about the Office’s role and mandate8% were about its investigation reports Two media interviews were granted​ Connecting with others In support of its vision, mission, and mandate, the Commissioner’s Office shares information, expertise, and best practices through organizations in Canada and other countries. Domestic outreach The Commissioner’s Office continues to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN). It is made up of federal, provincial, and territorial conflict of interest commissioners. The Commissioner, the Senior General Counsel and the Director of Communications, Outreach and Planning attended CCOIN’s September 2023 annual meeting. The Conflict of Interest Commissioner of Nova Scotia, Joseph P. Kennedy, hosted it in Halifax. The Commissioner also participated in CCOIN’s March 2024 online semi-annual meeting. In December, the Commissioner’s Office hosted interns from Quebec’s Fondation Jean-Charles-Bonenfant [link in French only]. International outreach The Commissioner’s Office is an active member of two international ethics organizations: The Réseau francophone d’éthique et de déontologie parlementaires (RFEDP), a group of public institutions in the Organisation internationale de la Francophonie [link in French only] that are involved in ethics and codes of conduct. The Council on Governmental Ethics Laws (COGEL), a U.S.-based organization of government ethics practitioners. RFEDP activities in 2023-2024: The Director of Advisory and Compliance continued to serve on the RFEDP’s Bureau.The Commissioner’s Office is a member of a working group on best practices that remained active. The Office continued to work with the RFEDP on a project to partner with universities on research about various topics. In June, the Director spoke at the École de printemps en études parlementaires : Éthique et déontologie [link in French only] at the University of Luxembourg.In July, the Director spoke at the 48th session of the Assemblée parlementaire de la Francophonie [link in French only] in Tbilisi, Georgia.In October, the Commissioner, the Director of Advisory and Compliance and the Director of Communications, Outreach and Planning attended the RFEDP’s Annual General Meeting in Quebec City. COGEL activities in 2023-2024: The Commissioner and several other Office representatives attended COGEL’s 2023 conference, held in Kansas City, Missouri, in December. The Director of Communications, Outreach and Planning was a member of the program committee for the conference, and moderated panels on data and generative AI, and academic collaboration.The Manager, Strategic Planning and Analysis, who co-chairs the Office’s Equity, Diversity, and Inclusion Committee, moderated an armchair discussion on equity, diversity, and inclusion. The Manager was also part of a panel on strategic planning. Other international outreach activities: Attended the 2024 Global Anti-Corruption and Integrity Forum of the Organisation for Economic Co-operation and Development. (March 2024)Presentation to the 15th Canadian Parliamentary Seminar in Ottawa. (March 2024)Meeting with Public Safety Canada to discuss their ongoing work on options to establish a foreign influence transparency registry (FITR). (December 2023)Meeting with a delegation from Vietnam. (November 2023)Meeting with Members of the European Parliament’s Committee on Constitutional Affairs. The Members are working to set up an ethics body that would bring in unified ethics and transparency standards across European Union institutions. (November 2023)Input to Global Affairs Canada for its response to a questionnaire from the APEC Anti-Corruption and Transparency Experts Working Group (ACTWG). The questionnaire was about how Asia-Pacific Economic Cooperation members have been implementing the APEC Anti-Bribery Principles. (May 2023) Managing the Commissioner's office A team of 53 people supports the Commissioner. They are experts in compliance, law, communications, information management and technology, investigations, parliamentary relations, and other areas. This team actively manages the day-to-day tasks involved in administering the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. It also makes sure the processes and structures are in place to support their administration. The Commissioner gives the Office overall direction and makes the decisions that need his input and approval. The Commissioner 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 post of Commissioner was vacant for much of the first five months of the fiscal year, after former Commissioner Mario Dion resigned in February 2023. Senior General Counsel Martine Richard served as Interim Commissioner from March 28 to April 19, 2023. On August 30, Konrad von Finckenstein was appointed Commissioner for a six-month term. Effective March 5, 2024, he was appointed for seven years. When the post was vacant, the Commissioner’s Office continued to do what was needed to support its mandate. For example, it advised public office holders, gave educational sessions and training, kept the public registry up to date, and responded to information requests. The Senior Management Committee gave guidance when necessary. It also kept working to comply with the Employment Equity Act and the Accessible Canada Act. Without a Commissioner, however, there were some things the Office could not do. For example, it could not issue reimbursement orders for blind trust fees, or decide whether to investigate matters that had come to its attention. As a first priority after Commissioner von Finckenstein’s appointment, the Office cleared the backlog of items that needed a Commissioner’s approval. To make sure it could function fully in the absence of a Commissioner in the future, Commissioner von Finckenstein delegated more authority to members of the Senior Management Committee. Improving the Office’s administrative efficiency was another priority. To make sure it has the right positions and the right people in them to support its mandate, the Office ran five staffing processes in 2023-2024. Employee turnover fell as just two employees left. The Office’s financial statements are audited each year by an independent external auditor. Its financial information for 2023-2024 is outlined in the Appendix. Appendix: Financial resources summary (thousands of dollars) Program Activity 2022-2023 2023-2024Alignment toGovernment of CanadaOutcomesActual 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 Commons6,7697,4217,4216,875Government AffairsContributions to employee benefit plans812912912839 Total spending7,5818,3338,3337,714 Plus: cost of services received without charge1,133N/AN/A1,017 Net cost of department8,7148,3338,3338,731 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 the Commissioner’s duties and functions under the Conflict of Interest Act in relation to public office holders, for the fiscal year ending March 31, 2024, 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 the Commissioner’s duties and functions under the Conflict of Interest Act in relation to public office holders for the fiscal year ending March 31, 2024, 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 report on the administration of the Conflict of Interest Act in 2023-2024. The Commissioner’s Office administers the Act and the Conflict of Interest Code for Members of the House of Commons. It does that by helping elected and appointed public officials avoid conflicts of interest. Ultimately, the goal is to safeguard public confidence in the integrity of Parliament and government institutions. The Office has a two-fold purpose. One, to help elected and appointed public officials avoid and manage conflicts of interest, and two, to facilitate the movement of qualified people in and out of public service. The Government of Canada benefits from a broad range of skills, experience, and perspectives when it appoints people from the private sector to various positions. The Act aims to encourage experienced and competent people to seek and accept public office, and to facilitate interchange between the private and public sectors. Like all experienced and competent people, those individuals will, over time, face potential conflicts of interest. While they are in public office, the Commissioner’s Office helps them avoid and manage such conflicts to protect the public interest. This means giving them credible, consistent, and timely advice. It also means being helpful and innovative, and making it as easy as possible for them to comply with the Act. It does not mean just looking for possible contraventions. If there is non-compliance, the Office works with public office holders to bring them back into compliance. If there is deliberate non-compliance, it will investigate and issue a report exposing the conflict. To achieve its mandate and mission, the Office must be as transparent as possible. It must communicate as openly as it can with Parliament and Canadians about what it does and why, and in a way people understand. Four changes were introduced in October to how the Office administers the Conflict of Interest Act. These changes of practice are based on common sense. They reflect our priority of applying the Act in a practical way to help public office holders avoid conflicts of interest. Please see section Helping public office holders comply for details. To help the Office run more efficiently, administrative processes were streamlined, and more authority was delegated to members of the Senior Management Committee. The Commissioner is the key decision maker, supported by employees of the Office. Employees must be empowered and equipped so they can work independently and efficiently on things that do not need to cross the Commissioner’s desk. The Office worked to make its communications and outreach activities more effective. It conducted its second survey of public office holders to better understand their needs. It continued using plain language to make its materials easy to understand and accessible. The Office testified six times before the House of Commons Standing Committee on Access to Information, Privacy and Ethics on various topics, to explain the workings of the Office. Our approach is reflected in the Office’s vision, mission, and mandate. They capture the why, what, and how of its activities. I look forward to building on this approach to the role of Commissioner in the years to come. Vision, mission, 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. Activities at a glance The Commissioner’s Office helps public office holders manage conflicts of interests during each of the three stages of their journey as they move in and out of public office. 1. When they are appointed Over 350 new or reappointed public office holders completed their initial compliance process. 2. While they are in office Over 2,600 instances of advice given every year about their individual circumstances. 3. When they leave Guidance documents shared over 520 times with public office holders when they were leaving office.​ The Office met the following service standards over 89% of the time: • 3 days to contact new or reappointed public office holders • 3 days to help public office holders when they reach out Data is based on a five-year average from April 1, 2019 to March 31, 2024. Public office holders Individuals covered by the Conflict of Interest Act are called public office holders. They must all meet its recusal requirement, its core set of conflict of interest rules, and its post-employment rules that apply indefinitely. Just over half of them (51%) must follow only those general rules. These public office holders without reporting obligations include part-time members of federal boards, commissions and tribunals appointed by the Governor in Council (the Governor General acting on the advice of Cabinet), and ministerial staff who work on average less than 15 hours a week. The rest (49%) have to follow additional rules. They must confidentially disclose certain information to the Office and publicly declare some information. They are restricted in their outside activities and they are not allowed to hold "controlled assets" such as publicly traded securities. They also face a cooling-off period after leaving public office. These reporting public office holders include ministers and parliamentary secretaries, ministerial staff who work on average 15 hours or more a week, and people appointed to full-time positions by the Governor in Council. As tracked in the Office’s quarterly statistical reports, the number of public office holders went up and down during the year: 349 reporting public office holders were appointed or reappointed, and 333 left office;341 public office holders without reporting obligations were appointed or reappointed, and 197 left office. At the end of 2023-2024, 6% more people were subject to the Act than the five-year average. All public office holders (snapshot as of March 31, 2024) Public office holders2,973Reporting public office holders - 1,46749%Public office holders without reporting obligations - 1,50651% Breakdown of public office holders (snapshot as of March 31, 2024) Reporting public office holders - 1,467Public office holders without reporting obligations - 1,506 39 ministers 39 parliamentary secretaries 829 ministerial staff 560 Governor-in-Council appointees 1,501 part-time members of federal boards, commissions and tribunals 5 ministerial staff who work on average less than 15 hours a week Public office holders over the past five years ​​2019-2020​ 2020-2021 2021-2022 2022-2023 2023-2024 Public Office holders without reporting obligations1,3801,5341,4511,4931,506Reporting public Office holders1,2881,3551,1061,4511,467 Helping public office holders comply The Conflict of Interest Act has many rules that public office holders must learn and follow to avoid conflicts between public and private interests. The Commissioner’s Office guides them on how to follow the rules. It also helps reporting public office holders identify and submit required information. That information helps the Commissioner’s Office spot possible conflicts of interest. To support transparency and prevent conflicts of interest, some of it is made public. The Commissioner’s Office reaches out to all public office holders early in their mandate. It aims to contact each one personally within three days after learning of their appointment or reappointment. It met this service standard 96% of the time in 2023-2024, more than its 80% target. Soon after they are appointed, it tells new public office holders without reporting obligations about the rules that apply to them. It also communicates with them from time to time while they are in office. In 2023-2024, it shared with them the 2022-2023 annual report under the Act, and invited them to six educational sessions. When the end of their term is coming up, it explains the Act’s post-employment rules that apply to them. Personal guidance The Commissioner’s Office works with reporting public office holders regularly while they are in office. It starts by assigning each one an advisor who can focus on their individual needs. This opens an ongoing dialogue that lasts for their time in office. Reporting public office holders can ask their advisor for advice at any time. Public office holders without reporting obligations can contact the Commissioner’s Office when they have questions. In a January 2024 survey, most public office holders identified access to an advisor as the Office’s biggest benefit. Their personal advisor helps them understand and follow the rules, and meet the Act’s reporting requirements. They also give them advice tailored to their personal situation. Initial compliance process Advisors walk newly appointed reporting public office holders through the initial compliance process. This is a critical step that they must complete to achieve compliance with the Act. It is an opportunity for them to learn the rules and address potential issues. Reporting public office holders must give the Commissioner’s Office a lot of personal and financial information, by filling out a Confidential Report. Their advisor reviews that information and helps them arrange their affairs to avoid conflicts of interest. For example, they may have to quit certain outside activities, or set up a conflict of interest screen. If they have controlled assets (publicly traded securities and other assets whose value could be directly or indirectly affected by government decisions or policy), they must sell them or put them in a blind trusts (“divest” them). The Commissioner’s Office will order their organization to pay them back for certain costs linked to blind trusts. Reimbursement rates are listed in an. Reimbursement rates are listed in an information notice that the Commissioner’s Office updated in February 2024. The Commissioner can let reporting public office holders who are not ministers or parliamentary secretaries keep some controlled assets. Their total market value must be so low there is no risk of conflict with their job duties. After capping this “minimal value exemption” at $30,000 for about 10 years, in October 2023 the Commissioner doubled it to $60,000. This is a more realistic amount given the changed economic situation and inflation. In October 2023, the Commissioner’s Office started letting people appointed to the Canada Energy Regulator deal with some assets differently. The​ Canadian Energy Regulator Act has a broader definition of conflict of interest than the Conflict of Interest Act. This was interpreted as meaning they had to sell any open-ended mutual funds and exchange-traded funds (ETFs) containing energy stocks. The Commissioner adopted a more liberal interpretation. Now, they can keep open-ended mutual funds, as these are exempt assets under the Conflict of Interest Act. They must still divest ETFs, as these are controlled assets under that Act. However, they now have the option of putting them in a blind trust instead of just selling them. The advisor prepares a summary of the information in the reporting public office holder’s Confidential Report (it is called a “summary statement”) for them to review and sign. When the Commissioner’s Office posts the summary statement in the public registry, the initial compliance process is over. This signals that the reporting public office holder has met their initial reporting obligations under the Act. They are now on track to maintain their compliance and avoid conflicts of interest going forward. Ongoing reporting requirements Reporting public office holders must tell the Commissioner’s Office about any gifts or other advantages worth $200 or more that they or a family member accept. These could include event invitations and tickets, meals, services, property, or the use of property at a reduced rate or no cost. Public office holders and their family members may not accept gifts that might reasonably be seen to have been given to influence the public office holders in how they do their job. There are several exceptions to this rule. One is for gifts that are within the customary standards that normally accompany a public office holder’s position. Since October 2023, the Commissioner has allowed them, under that exception, to accept certain gifts worth $40 or less, with a yearly cap of $200 worth of such gifts from one donor. This change mirrors the exemption in the new Lobbyists’ Code of Conduct (2023). Reporting public office holders must also tell the Commissioner’s Office about: Changes to the information in their Confidential Report. These are called material changes. Recusals (when they stepped back from talking about, deciding on, debating, or voting on anything they might have a conflict of interest in). All public office holders must recuse if they have a conflict of interest, but only reporting public office holders have to tell the Office about such recusals.Firm offers of outside employment and their acceptance. If a reporting public office holder is considering an offer, their advisor can tell them if accepting it would violate the Act’s post-employment rules. Since October 2023, outside employment does not include jobs or contracts with federal public sector entities other than the Senate or House of Commons. In 2023-2024, reporting public office holders disclosed to the Commissioner’s Office over 20 firm offers of outside employment and their acceptance.Private flights accepted by ministers and parliamentary secretaries, a member of their family, a ministerial adviser, or ministerial staff. They can only accept private flights if required for their job, in exceptional circumstances, or with the Commissioner's prior approval. Some of this information will be made public. Reporting public office holders must also complete an annual review. Every year, they must review their information with their advisor, and update it as needed. Advice The Commissioner’s Office advises public office holders on issues that may involve potential conflicts of interest. It encourages them to get in touch any time they have questions or concerns. In 2023-2024, the Office received 8% more requests for advice than the five-year average. The Office aims to respond to public office holders’ requests for advice within three business days. It met this service standard 93% of the time in 2023-2024, more than its 80% target. To make sure the advice it gives public office holders is consistent, the Commissioner’s Office records how the Commissioner interprets the Act in an internal practice manual. It launched a major update of this tool in 2023-2024. The Commissioner’s Office also tracks the kinds of things public office holders 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 public office holder positions. Post-employment After they leave public office, former public office holders must follow the Act’s post-employment rules. There is a cooling-off period of two years for former ministers and one year for other former reporting public office holders. During that time, they may not contract with or accept a job offer from an entity they had direct and significant official dealings with during their last year in office. Since October 2023, the Commissioner’s Office has excluded federal public sector entities from the Act’s definition of entity. This means, for example, that reporting public office holders no longer need to ask for an exemption, reduction, or waiver of their cooling-off period to accept such work. The change recognizes that the government is one entity, and there cannot be any conflicts of interest between different parts of it. 2023-2024 in numbers The Commissioner’s Office helps public office holders understand the rules and arrange their affairs, so they can avoid conflicts of interests at every stage: when they enter public office, while they are in office, and after they leave it. Helping public office holders understand the rules in the Conflict of Interest Act 341 emails outlining rules and obligations sent to new and reappointed public office holders without reporting obligations349 emails outlining rules and obligations sent to new and reappointed reporting public office holders Helping reporting public office holders arrange their affairs to avoid conflicts of interests 305 initial compliance processes completed 1,241 annual reviews completed 2,767 instances of advice provided778 public registry postings (includes postings related to initial compliance and ongoing obligations)83% 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 deadline9 conflict of interest screens set up49 divestments of controlled assets (37 by sale and 12 by blind trust)150 reimbursement orders issued for blind trust fees totalling $790,000 Helping former public office holders avoid conflicts of interests after they leave 197 post-employment reminders sent to former public office holders without reporting obligations 333 post-employment reminders sent to former reporting public office holders 305 individuals were still subject to a cooling-off period at the end of the fiscal year2 post-employment exemptions, waivers or reductions granted Advice by topic in 2023-2024 Requests for advice from individuals subject to the Act 2,767 General obligations 851 Material changes 839 Post-employment obligations 407 Gifts or other advantages 380 Outside activities 290 Requests for advice over five years (five-year average: 2,559) 2019-2020 2020-2021 2021-2022 2022-2023 2023-2024 1,9412,2373,3492,5012,767 Public declarations by public office holders in 2023-2024 Public declarations by topic 765 Summary statements 271 Outside activities 153 Gifts or other advantages 146 Assets 103 Liabilities 49 Recusals 38 Travel 5 Educating and informing Prevention is a major focus of the Conflict of Interest Act. Public office holders must learn the rules so they can recognize potential conflicts of interest and take steps to avoid them. The Commissioner’s Office helps them understand what they must—and must not—do to avoid conflicts of interest. It offers education and training on the Act’s conflict of interest rules and its other requirements. To help public office holders understand and retain important information, the Office gives them the same information more than once, and in different ways. Soon after they are appointed, the Commissioner’s Office gives every public office holder some general information. That information helps them understand the Act. It also helps them know when they should ask their advisor questions. The Commissioner’s Office also gives educational sessions and presentations to groups of public office holders. In 2023-2024, it gave 24 of these, mostly online. Over 300 public office holders participated. This is in line with the number of presentations offered the year before. Six of those educational sessions and presentations were to: ministers’ offices (Indigenous Services Canada, Crown-Indigenous Relations and Northern Affairs Canada); andorganizations with public office holders (Elections Canada, Invest in Canada). The other 18, attended by over 170 participants, were for groups of public office holders from across a range of organizations. The Office organizes educational sessions like these in a purposeful way and delivers them on a regular basis. Regularly scheduled educational sessions Topic Audience What is a conflict of interest? Reporting public office holders appointed in last 60 days Overview of the Act Public office holders appointed in last 120 days General information New reporting public office holders General information Ministerial staff In July 2023, the Commissioner’s Office gave a presentation to members of the Privy Council Office’s appointments staff. The Privy Council Office directs potential Governor in Council appointees to the Commissioner’s Office for information about the Act’s requirements. It also tells new public office holders about educational sessions offered by the Commissioner’s Office. In January 2024, the Director of Communications, Outreach, and Planning gave a presentation to a Carleton University class. The students included current and future public office holders and ethics practitioners. The Office’s strategic communications and engagement plan is a framework for all these activities. It is aimed at meeting the needs of public office holders, a primary audience. Actions in the plan are designed to help the Commissioner’s Office give them the information they need promptly, and in the formats they prefer. The Office also accepts all on-demand requests for presentations. 2024 public office holders survey In January 2024, the Commissioner’s Office surveyed public office holders to better understand their needs. It wanted to know what worked well when communicating and engaging with them. Just as important, it also wanted to know how it could do better. The Office ran the same kind of survey in 2022. The survey results confirmed its approach in areas like education and training. They also showed there is room for improvement. The Commissioner's Office will use the results to build on what is working, and to make any needed changes. For example, improving educational opportunities and simplifying its communications. Survey highlights Public office holders continued to have a positive opinion of the Commissioner’s Office and were satisfied with their interactions.A large majority continued to strongly agree that advisors are courteous and helpful, and that they provide useful, timely and accurate information. They also indicated that access to an advisor is the Office’s greatest value-add.A large majority said getting emails from the Office is more helpful than getting information from its website.A small minority were dissatisfied with the rules.Respondents said they would like more training options. The survey responses represent the views of all public office holders at a 95% confidence level. Addressing non-compliance The Commissioner’s Office upholds the Conflict of Interest Act’s focus on prevention by helping public office holders avoid conflicts of interest. It also helps them meet the Act’s other requirements, like disclosing information and arranging their private affairs. Sometimes, however, public office holders fail to comply with the Act. This can happen for all kinds of reasons, including some that are not in their control. It is rare for someone to deliberately ignore their obligations under the Act, or to refuse to cooperate with the Commissioner’s Office. When a public office holder does not comply with the Act, their advisor in the Commissioner's Office works with them to get them back on track. The Office also helps former reporting public office holders follow the Act’s post-employment rules. They can call the Office for post-employment advice at any time after they leave public office, even years later. Former reporting public office holders do not have to tell the Commissioner’s Office about any new jobs they accept, so it monitors sources of public information about their employment activities. If the Office spots any risk of conflict of interest, it steps in with advice. The involvement of the Commissioner’s Office usually solves issues of non-compliance. If it does not, there are some enforcement mechanisms the Office can use, depending on the circumstances. Administrative monetary penalties There are deadlines in the Act for getting information to the Commissioner’s Office, and penalties for missing them. Under sections 52 and 53 of the Act, the Commissioner can impose administrative monetary penalties of up to $500 for not meeting certain reporting requirements on time. Penalties are posted in the public registry. Compliance orders Under section 30 of the Act, the Commissioner may order a public office holder to take any measure to comply with it. Compliance orders cover things like submitting documents for an annual review, divesting controlled assets or quitting prohibited activities. They are posted in the public registry. Investigations The Commissioner can investigate public office holders if it looks like they may have contravened the Act. (Investigations under the Act are called “examinations.”) Under section 44 of the Act, the Commissioner must investigate if asked by a Senator or Member of the House of Commons who provides reasonable grounds to believe the Act has been contravened. The Office received six examination requests from Members in 2023-2024. Under section 45, the Commissioner may take the initiative to investigate something if there is reason to believe a current or former public office holder has broken the rules. The Commissioner may decide to investigate under section 45 of the Act based on information from media reports or complaints from members of the public, among other sources. The Commissioner’s Office received 11 examination requests from members of the public in 2023-2024. The Commissioner reports publicly on completed examinations. These examination reports can be found on the Office’s website, and in the public registry. When the Commissioner discontinues an examination launched under section 44 of the Act, a discontinuance report is issued. However, when an examination launched under section 45 is discontinued, the Commissioner decides whether to issue a report. The Commissioner reports on examinations under the Act to the Prime Minister. No examination reports were issued in 2023-2024. As of March 31, 2024, the Commissioner’s Office was working on two examinations.​ 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 or not an examination is launched. In 2023‑2024, the Commissioner’s Office did not report on any referrals from the Public Sector Integrity Commissioner. Case files The Commissioner’s Office sometimes receives information that someone may have contravened the Conflict of Interest Act. That 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. Some of these reviews may lead to examinations. When the Commissioner’s Office finds an examination is not warranted, it closes the case file. 2023-2024 in numbers Administrative monetary penalties Two $200 penalties paid for failing to disclose a material changeTwo $250 penalties paid for failing to disclose a material change Case files (a case file is a concern that is reviewed by the Office) Total case files: 19 Ongoing: 3Closed without an examination: 16Closed with publication of report: 0 Breakdown of case files Subject of each case file Current or former minister and parliamentary secretary 7 Current or former public office holder 11 Person not subject to the Act 1 Source of these case files Member of the House of Commons 6 Office of the Public Sector Integrity Commissioner 0 Media 2 Member of the general public 11 Within the Office 0 Nature of the concern* Furthering a private interest (subsection 6(1) of the Act) 10 Duty to recuse (section 21) 6 Post-employment rules (sections 33 to 35) 0 Influence (section 9) 8 Preferential treatment (section 7) 1 Private air travel (section 12) 0 Prohibited activities (section 15) 2 Public declaration (section 25) 3 Insider information (section 8) 0 Gifts and other advantages (section 11) 1 Material changes (section 22) 0 *A case file can have more than one concern Reporting to Parliament The Conflict of Interest and Ethics Commissioner has a duty to report to Parliament, testify before parliamentary committees, and answer questions from Parliament. The Commissioner reports on behalf of Canadians to Parliament directly, not through a minister. This is because the Commissioner is an independent Officer of the House of Commons. By June 30 each year, the Commissioner must send an annual report on the administration of the Conflict of Interest Act to the Speakers of the Senate and the House of Commons. The Speakers table it in those chambers. The Office sends communiqués to parliamentarians about reports and other activities under the Act and the Conflict of Interest Code for Members of the House of Commons. It sent three communiqués in 2023-2024. The House of Commons Standing Committee on Access to Information, Privacy and Ethics (ETHI) has oversight responsibility for the Office. It reviews the Office’s annual spending estimates, and matters related to the Commissioner’s reports under the Act. In 2023-2024, the Commissioner and other senior Office representatives appeared before ETHI six times. ETHI appearances Subject Main Estimates 2023-24: Vote 1 under Office of the Conflict of Interest and Ethics Commissioner Date May 12, 2023 Appearing Sandy Tremblay, Director, Corporate ManagementMelanie Rushworth, Director, Communications, Outreach and Planning​ Subject Appointment of the Hon. Navdeep Bains as Chief Corporate Affairs Officer at Rogers Communications Date June 20, 2023 Appearing Lyne Robinson-Dalpé, Director, Advisory and Compliance Subject Briefing session with the Interim Conflict of Interest and Ethics Commissioner Date September 18, 2023 Appearing Commissioner Konrad von FinckensteinWith Lyne Robinson-Dalpé, Director, Advisory and Compliance Subject Briefing on Annual Reports and Other Reports of the Conflict of Interest and Ethics Commissioner Date October 16, 2023 Appearing Commissioner Konrad von Finckenstein(Former Commissioner Mario Dion also appeared) Subject Briefing Session with the Conflict of Interest and Ethics Commissioner Date January 30, 2024 Appearing Commissioner Konrad von FinckensteinWith Lyne Robinson-Dalpé, Director, Advisory and Compliance​ Subject Decision of the Royal Canadian Mounted Police (RCMP) to Not Pursue a Criminal Investigation in Relation to the SNC-Lavalin Affair Date March 21, 2024 Appearing Commissioner Konrad von FinckensteinWith Michael Aquilino, Legal Counsel(Former Commissioner Mario Dion also appeared)​​ Supporting transparency Transparency is like a window that lets people see how things work. It is a pillar of the Conflict of Interest Act and, indeed, of all effective conflict of interest regimes. Ultimately, it can promote trust in government decision making. Public office holders must not only follow the rules in the Act, they must be seen to do so. By seeing how things work, Canadians can feel confident that the government is doing what it is supposed to do. To keep the government accountable, Parliament and Canadians need access to clear, accurate and up-to-date information. Transparency is built into the Act through its disclosure and public declaration requirements. Reporting public office holders must give the Commissioner information about their financial interests, personal relationships, and other factors that could potentially influence their decision making. Public registry Some of that information is made public. The Act requires the Commissioner’s Office to maintain a public registry. This searchable database contains all the information about individual public office holders that the Commissioner is allowed to make public. Reporting public office holders’ information stays in the registry until the end of their one- or two-year cooling-off period under the Act’s post-employment rules. After that, it is no longer available from the Office. Public communications The Commissioner’s Office also aims for transparency in its public communications. By law, it must keep some information—like any dealings it has with individual public office holders—private. But it shares as much information as it can, and in different ways. For example, the Office posts information on its website and on social media, and responds to media and members of the public who ask for information. The Office uses social media to keep track of conversations about ethics issues. It also shares information about its activities and the public registry on social media. The Office aims its messaging at educating its secondary audiences: media, academics, international and domestic ethics practitioners, and others who are interested in what it does. It communicates with public office holders in other ways. When responding to inquiries from media and members of the public, the Office gives as much information as possible about how the Act works. It also includes links to the public registry when appropriate. The Office only answers emails that are directly addressed to it, not ones it is just copied on. The Office aims to respond to media inquiries within four hours, and to inquiries from members of the public within 10 business days, at least 80% of the time. In 2023-2024, it met these service standards 96% of the time for media inquiries, and 91% of the time for public inquiries. The Office is also transparent about its activities. It publishes quarterly statistical reports that show, for example, how many times it responded to public office holders’ requests for advice, and what it is doing in the area of education. These reports also include figures on how it meets its service standards. 2023-2024 in numbers Public registry Almost 1,300 items posted, in line with the five-year average Over 120,000 public registry page views, up 40% from the year before Website 51,000 new users, up 22% from the year before 200,000 page views, up 35% from the year before About 59% of website traffic resulted from Internet searches. This could mean that people were interested in the work of the Office and decided to access the website that wayThe Office’s emails, social media posts and media advisories drove most of the rest of the users to the website Social media The Office’s X followers grew by 8% to 4,284It tweeted 30% less than in the previous yearIts LinkedIn followers rose from 35 to 599 Public inquiries The Office received over 3,100 emails and phone calls from members of the public Media inquiries The Office received and responded to over 140 media requests, up 23% Almost a third of these requests resulted in an article or social media mention 50% were questions about a specific public office holder or Member of the House of Commons, or the status of a current case file42% were general inquiries about the Office’s role and mandate8% were about its investigation reports Two media interviews were granted​ Connecting with others In support of its vision, mission, and mandate, the Commissioner’s Office shares information, expertise, and best practices through organizations in Canada and other countries. Domestic Outreach The Commissioner’s Office continues to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN). It is made up of federal, provincial, and territorial conflict of interest commissioners. The Commissioner, the Senior General Counsel and the Director of Communications, Outreach and Planning attended CCOIN’s September 2023 annual meeting. The Conflict of Interest Commissioner of Nova Scotia, Joseph P. Kennedy, hosted it in Halifax. The Commissioner also participated in CCOIN’s March 2024 online semi-annual meeting. In December, the Commissioner’s Office hosted interns from Quebec’s Fondation Jean-Charles-Bonenfant [link in French only]. International Outreach The Commissioner’s Office is an active member of two international ethics organizations: The Réseau francophone d’éthique et de déontologie parlementaires (RFEDP), a group of public institutions in the Organisation internationale de la Francophonie [link in French only] that are involved in ethics and codes of conduct. The Council on Governmental Ethics Laws (COGEL), a U.S.-based organization of government ethics practitioners. RFEDP activities in 2023-2024: The Director of Advisory and Compliance continued to serve on the RFEDP’s Bureau.The Commissioner’s Office is a member of a working group on best practices that remained active. The Office continued to work with the RFEDP on a project to partner with universities on research about various topics. In June, the Director spoke at the École de printemps en études parlementaires : Éthique et déontologie [link in French only] at the University of Luxembourg.In July, the Director spoke at the 48th session of the Assemblée parlementaire de la Francophonie [link in French only] in Tbilisi, Georgia.In October, the Commissioner, the Director of Advisory and Compliance and the Director of Communications, Outreach and Planning attended the RFEDP’s Annual General Meeting in Quebec City. COGEL activities in 2023-2024: The Commissioner and several other Office representatives attended COGEL’s 2023 conference, held in Kansas City, Missouri, in December. The Director of Communications, Outreach and Planning was a member of the program committee for the conference, and moderated panels on data and generative AI, and academic collaboration.The Manager, Strategic Planning and Analysis, who co-chairs the Office’s Equity, Diversity, and Inclusion Committee, moderated an armchair discussion on equity, diversity, and inclusion. The Manager was also part of a panel on strategic planning. Other international outreach activities: Attended the 2024 Global Anti-Corruption and Integrity Forum of the Organisation for Economic Co-operation and Development. (March 2024)Presentation to the 15th Canadian Parliamentary Seminar in Ottawa. (March 2024)Meeting with Public Safety Canada to discuss their ongoing work on options to establish a foreign influence transparency registry (FITR). (December 2023)Meeting with a delegation from Vietnam. (November 2023)Meeting with Members of the European Parliament’s Committee on Constitutional Affairs. The Members are working to set up an ethics body that would bring in unified ethics and transparency standards across European Union institutions. (November 2023)Input to Global Affairs Canada for its response to a questionnaire from the APEC Anti-Corruption and Transparency Experts Working Group (ACTWG). The questionnaire was about how Asia-Pacific Economic Cooperation members have been implementing the APEC Anti-Bribery Principles. (May 2023)​ Managing the Commissioner's office A team of 53 people supports the Commissioner. They are experts in compliance, law, communications, information management and technology, investigations, parliamentary relations, and other areas. This team actively manages the day-to-day tasks involved in administering the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. It also makes sure the processes and structures are in place to support their administration. The Commissioner gives the Office overall direction and makes the decisions that need his input and approval. The Commissioner 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 post of Commissioner was vacant for much of the first five months of the fiscal year, after former Commissioner Mario Dion resigned in February 2023. Senior General Counsel Martine Richard served as Interim Commissioner from March 28 to April 19, 2023. On August 30, Konrad von Finckenstein was appointed Commissioner for a six-month term. Effective March 5, 2024, he was appointed for seven years. When the post was vacant, the Commissioner’s Office continued to do what was needed to support its mandate. For example, it advised public office holders, gave educational sessions and training, kept the public registry up to date, and responded to information requests. The Senior Management Committee gave guidance when necessary. It also kept working to comply with the Employment Equity Act and the Accessible Canada Act. Without a Commissioner, however, there were some things the Office could not do. For example, it could not issue reimbursement orders for blind trust fees, or decide whether to investigate matters that had come to its attention. As a first priority after Commissioner von Finckenstein’s appointment, the Office cleared the backlog of items that needed a Commissioner’s approval. To make sure it could function fully in the absence of a Commissioner in the future, Commissioner von Finckenstein delegated more authority to members of the Senior Management Committee. Improving the Office’s administrative efficiency was another priority. To make sure it has the right positions and the right people in them to support its mandate, the Office ran five staffing processes in 2023-2024. Employee turnover fell as just two employees left. The Office’s financial statements are audited each year by an independent external auditor. Its financial information for 2023-2024 is outlined in the Appendix. Addressing legal matters 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 2023-2024. Democracy Watch 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 be a conflict does not contravene the rules. In the Notice of Application for Judicial Review it submitted to the Court, Democracy Watch pointed out mistakes 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. Democracy Watch also asked for a certified copy of everything the Commissioner looked at in the investigation (called the “certified tribunal record”). 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. Section 66 is the Act’s privative clause, a provision that aims to limit or exclude judicial review of decisions. In a motion to strike the Notice of Application, the Attorney General also wrote that section 66 does not allow the Court to review the alleged errors of law and fact. 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). Democracy Watch filed a specific motion to get the certified tribunal record. The Attorney General objected, noting that much of the material is confidential. In a second decision, the judge wrote that the Commissioner should not be required to disclose confidential documents in support of a ground that the Court might not be allowed to review because of section 66 (Democracy Watch v. Canada [Attorney General], 2023 FCA 39). The judge decided that the Court should therefore proceed in two stages: In stage 1, the full panel of the Court will determine how section 66 of the Act applies to the matter. If the Court determines that section 66 applies, it may dismiss Democracy Watch’s application. If it determines that some or all of the grounds are allowed, it may move on to stage 2 and review the application on its merits. The Federal Court of Appeal heard Stage 1 on March 24, 2024. It has not yet made a decision. Appendix: Financial resources summary (thousands of dollars) Program Activity 2022-2023 2023-2024Alignment toGovernment of CanadaOutcomesActual 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 Commons6,7697,4217,4216,875Government AffairsContributions to employee benefit plans812912912839 Total spending7,5818,3338,3337,714 Plus: cost of services received without charge1,133N/AN/A1,017 Net cost of department8,7148,3338,3338,731 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 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 the Commissioner’s duties and functions under the Conflict of Interest Code for Members of the House of Commons for the fiscal year ending March 31, 2023, 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, Honourable Konrad W. von Finckenstein, C.M., K.C.Interim Conflict of Interest and Ethics Commissioner​ 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 2022‑2023. Notably, the Office expanded its focus on education and training during the year. It started implementing a strategic communications and engagement plan that includes ways to better understand Members’ needs so it can make its communications and outreach activities more effective. Actions in the plan help the Office give Members the information they need, when they need it and in the way they want to receive it so they can effectively manage conflict of interest issues. The Office also continued to give Members confidential advice and direction. The Office carried out its mandate in 2022-2023 through these and other actions.​​ I only came to this role in September 2023, so everything reported here was accomplished under previous leadership. And of course, it rests on the efforts of the Office’s employees. I am honoured to serve Parliament and Canadians and look forward to helping the Office continue its work. The Code and the Conflict of Interest Act are important accountability tools that help prevent public office from being used for private gain and support transparency. I will bring my experience and judgment to bear in administering them. Our Vision Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament. Our Mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act​.​ Our Stakeholders Regulatees are key stakeholders of the Office. They are the people who are subject to the conflict of interest regimes it administers. Stakeholders also include Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report touches on all stakeholder groups but focuses on the elected officials who are covered by the Conflict of Interest Code for Members of the House of Commons​. In October 2022, the Office surveyed Members. The aim was to help it better communicate and engage with them so they understand how to comply with the Code. The survey was confidential and anonymous. The results were analyzed and the main findings were shared with all Members. The Office’s quarterly statistical reports show how the number of Members varied during the year. The following graph is a snapshot of Members on March 31, 2023.​ Members of the House of​ Commons333 Members of the House of Commons who are not ministers or parliamentary secretaries ​256 ​​Ministers* 39 ​Parliamentary secretaries*38​ ​*Also subject to the Conflict of Interest Act Our Achievements Key activities Reporting to ParliamentReporting to Parliament and testifying before its committees​ComplianceHelping regulatees achieve and maintain compliance with the conflict of interest regimesDirection and adviceGiving regulatees confidential guidance tailored to their individual situationsEducation and outreachHelping regulatees understand their obligations under the regimesEnforcementApplying investigation and other enforcement provisions of the regimes as appropriatePublic communicationsEducating and informing regulatees, the media and the general publicCollaboration and best practicesExchanging information with domestic and international counterparts Reporting to Parliament The Conflict of Interest and Ethics Commissioner has a duty to report to Parliament, testify before parliamentary committees and answer questions from Parliament. The Commissioner reports on behalf of Canadians to Parliament directly, not through a minister. This reflects the Commissioner’s independence as an Officer of the House of Commons. The Commissioner sends reports under the Conflict of Interest Code for Members of the House of Commons to the Speaker of the House of Commons. The Speaker tables them in the House. The Commissioner reports on inquiries under the Code to the House of Commons. The Commissioner sends a list of sponsored travel under the Code to the Speaker of the House by March 31 each year. 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 List of Sponsored Travel 2022​ was tabled in the House of Commons on March 30, 2023. It showed that sponsored travel accepted by Members started to return to pre-pandemic levels. After accepting just seven sponsored trips for themselves and their guests in each of the previous two years, Members accepted 55 in 2022. By June 30 each year, the Commissioner must send an annual report on the administration of the Code to the House. The Office cannot submit the report in the absence of a Commissioner. The Office sends communiqués to parliamentarians when it issues reports under the Code and under the Conflict of Interest Act, as well as advisory opinions. It sent 10 communiqués in 2022-2023. The House of Commons Standing Committee on Procedure and House Affairs has responsibility for the Code. It did not invite former Commissioner Mario Dion to testify in 2022‑2023. Changes to the Code Under section 33 of the Code, the House of Commons Standing Committee on Procedure and House Affairs must review the Code’s provisions and operation every five years and report on each review to the House. On June 21, 2022, the Committee reported to the House on its review of the Code that began in February of that year. On March 30, 2023, the House approved the Committee’s report and its 13 recommendations came into effect, amending the Code. The Office immediately started planning a series of projects to implement those amendments. It will include an update in its 2023-2024 annual report under the Code.​ Compliance​ To support its mission to ensure full compliance with the conflict of interest regimes it administers, the Office uses most of its resources to help regulatees follow the rules. Employees in the Advisory and Compliance division help Members comply with the Conflict of Interest Code for Members of the House of Commons. They give Members the information they need to understand the rules and what they must do to meet them, as well as confidential direction and advice. That guidance is sometimes based on legal opinions prepared by the Investigations and Legal Services division. To meet the Code’s transparency requirements, the Office posts in the public registry some of the information submitted by Members. The Office guides Members proactively, giving them direction on issues that involve real or potential conflicts of interest. It also encourages them to consult the Office if they have questions or concerns. Advisors will give them advice based on the facts at hand, with input from the Commissioner as needed. That advice may reflect precedents confirmed by the Commissioner. The Office offers Members educational sessions about how to comply with the Code. It also offers annual training for Members who are ministers or parliamentary secretaries to help them identify potential conflicts of interest. As a result of the March 2023 changes to the Code, Members will have to attend mandatory training after they are elected. The Office’s contact with Members starts within three days after their name is published in the Canada Gazette or earlier if they contact the Office. It continues the whole time they are in office. How does the Offic​e help Members comply with the Code? ​By giving them advice when they need it866 instancesBy posting their declarable information in the public registry468 postings​By contacting them annually183 reviews​​​By ensuring they complete their initial compliance process83 processes​​By contacting them as soon as they are elected1 communication Initial Compliance Process All Members must complete an initial compliance process under the Conflict of Interest Code for Members of the House of Commons. This means they have to give the Office certain information. When they disclose their information, advisors can help them address potential issues. Advisors also help them learn the rules. Once they complete the process, it is easier for them to comply with the Code going forward. Members can also ask the Office for advice at any time. Initial compliance is a two-stage process. The first stage starts soon after a Member is elected or re-elected in a general election or by-election, when their name is published in the Canada Gazette. They have 60 days to give the Commissioner a confidential disclosure statement with their information and that of their spouse and dependent children. An advisor in the Office reviews the disclosure statement and advises the Member on how to comply with the Code. The advisor may recommend specific measures to prevent conflicts of interest. They then prepare a summary of the information in the disclosure statement for the Member to review and sign. The second stage starts when the Member receives their disclosure summary. They have 60 days to review and sign it. The Office then posts the Member’s disclosure summary in the public registry. Once the information is posted, the initial compliance process is over. The Office maintains a Members’ Compliance Status Report that shows where each Member is in the initial compliance process. Once they have completed the initial compliance process, Members are on track to avoid any conflicts of interest while they are in office. They are welcome to contact the Office for confidential advice at any time. Some processes may have been started in one fiscal year and completed in the next. Initial compliance process for Members of the House of Commons Helping new reporting public office holders comply with the ActInformingThe Office sends the Member an email or letter telling them about the rules and what they need to do​.FilingThey must file a disclosure statement listing things like assets, debt and income within 60 days.ExplainingAn advisor reviews the disclosure statement and calls the Members to discuss their file.SigningThe advisor sends them an email or letter that identifies any extra steps needed and includes a disclosure summary for them to sign within 60 days.FinalizingThe Member signs the summary and take any extra steps required.(83 Initial compliance processes completed) The process is completed when the information is added to the public registry. Ongoing Reporting Requirements Completing the initial compliance process under the Conflict of Interest Code for Members of the House of Commons is just the first step. Members also have to meet other reporting requirements while they are in office. For example, they must let the Office know about any change to the information in their disclosure statement, within 60 days. These “material changes” could include buying or selling a house or car, getting or paying off a loan, or any new ties between relatives or friends and government entities. When Members disclose these kinds of information to the Office, advisors can help them prevent conflicts of interest. They may also have to amend their disclosure summary.​ Ongoing reporting requirements Annual review 183 ​​annual reviews initiated and 103 received Material changes Gifts and other benefits Sponsored travel ​Sponsored travel totalled $422,015.79 in calendar year 2022Private interests Public Registry The Office maintains a public registry of all the information about individual regulatees that the Commissioner is authorized to make public. It is a searchable database that is often accessed by regulatees, the media, members of the public, governments, and ethics practitioners around the world. In 2022‑2023, the Office posted almost 1,400 items for all regulatees in the public registry, up 10% from the year before. There were over 80,500 public registry page views in 2022‑2023, almost a third more than the year before. In the past few years, there has been an overall increase in the number of public registry visits, with a significant spike in the first and last quarters of 2022‑2023. To promote transparency, the Office has drawn attention to the public registry in its public communications. This continued increase in the number of visits reflects greater interest in and knowledge of the Office’s mandate and the regimes it administers. What did Members of the House of Commons declare in 2022-2023? 2022-2023Disclosure summaries250Material changes108Sponsored travel (calendar year)58Gifts and other benefits51Private interests1 Direction and Advice Prevention is a major focus of the Conflict of Interest Code for Members of the House of Commons. Members must learn the rules so they can recognize possible conflicts of interest and take steps to avoid them. The Office guides Members proactively, giving them direction on issues that involve real or potential conflicts of interest. It also encourages them to consult the Office if they have questions or concerns. Advisors will give them advice based on the facts at hand. That advice may reflect precedents confirmed by the Commissioner or result from consultation with the Commissioner. The Commissioner reviews in advance all advice for Members who are ministers or parliamentary secretaries. The Office responded to over 850 requests for advice from Members in 2022‑2023, up 43% from the year before. Many of those requests were about gifts. The Office makes sure the confidential advice it gives Members is clear and consistent. Advice reflects their personal circumstances, so different advice may be given in cases that appear similar. The Office ensures consistency by recording the Commissioner’s interpretations of the Code in an internal practice manual that advisors can consult and by adding Members’ requests for advice to their files. The Office tracks the types of advice requested so it can spot trends that may impact its workload and identify training needs. What did Members of the House of Commons ask about? 2022-20232021-2022Material changes272255General obligations199220Gifts and other benefits33782​Letters of support and fundraising5848 Education and Outreach Members of the House of Commons are key stakeholders of the Office. One of its strategic objectives is to increase the trust key stakeholders have in the Office and the Office’s credibility in their eyes. The idea is for them to become stronger allies in the delivery of its mandate and to be able to effectively manage conflict of interest issues. The Commissioner also has a specific mandate under section 32 of the Conflict of Interest Code for Members of the House of Commons to educate Members and the general public about the Code and the Commissioner’s role. In 2022‑2023, the Office started implementing a strategic communications and engagement plan to help achieve that objective. The plan includes ways to better understand the needs of the Office’s audiences so it can make its communications and outreach activities more effective. Members are part of its primary target audience, so the Office reaches them in different ways than the media, academics, domestic and international stakeholders and others. Actions in the plan will help the Office give Members the information they need, when they need it and in the way they want to receive it. The Office sometimes issues advisory opinions under subsection 26(4) of the Code to help Members comply with it in specific situations. In November 2022, it issued one to explain how to meet the Code’s rules when making recommendations about how grants under the Canada Summer Jobs program and similar programs are allocated in their ridings. In January 2023, it issued an advisory opinion about the gift of a radon detector offered to all Members.​ Enforcement The Commissioner can investigate possible contraventions of the Conflict of Interest Code for Members of the House of Commons. Investigations under the Code are called “inquiries.” All inquiry reports​ are made public. Inquiries can start in three ways: Any Member who has reasonable grounds to believe another Member has contravened the Code may ask the Commissioner to investigate by submitting a written request​ that meets the requirements set out in the Code. When the Office receives a valid request from a Member, it follows a process​ set out in the Code to decide if an inquiry is warranted.The House of Commons may also direct the Commissioner to conduct an inquiry. This has not happened since the Code was adopted in 2004.The Commissioner may self-initiate an inquiry if the Commissioner has reason to believe a Member has contravened the Code. The Commissioner’s decision may be based on information from various sources, including media reports and complaints from members of the public. No inquiries were underway as of March 31, 2023. One inquiry remains suspended. The Office did not issue any inquiry reports in 2022‑2023. Sanctions The Commissioner cannot impose sanctions under the Code. However, under section 28 of the Code, the Commissioner may recommend in inquiry reports that the House of Commons impose appropriate sanctions. This is because only the House has the right to discipline its own Members. It is responsible for imposing and administering sanctions, including any that may be recommended by the Commissioner. Case Files ​under the Code When the Office receives information about a possible contravention of the Code, whether from a Member of the House of Commons, media reports, or complaints from members of the public, it may open a case file. When a case file is opened, the Office conducts an initial review of the matter. Some of these reviews may lead to inquiries. When an inquiry is not found to be warranted, the case file is closed.​ Case files under the Act in 2022-2023 How many case files were opened and closed?​Total case files (a case file is a concern that is reviewed by the Office)​11Ongoing or suspended 4Closed without an inquiry 7Closed with publication of report0Who was the subject of each case file?*​Current or former Member of the House of Commons 13Person not subject to the Code0What was the source of these case files?Member of the House of Commons4Within the Office2Member of the general public4Media1What was the nature of the concern?*​Furthering a private interest4Influencing a decision or attempting to influence a decision 8Disclosure of information 3Attempt to engage in prohibited activities 6Sponsored travel 0​​Gifts and other benefits 2 ​​​*Some case files have more than one subject or concern As of March 31, 2023, the Office was not working on any active inquiries under the Code. One inquiry remains suspended. Public Communications​​ The Office shares information on its website, is active on social media, responds to inquiries from the media and members of the public, and delivers presentations to the interested public. The goal is to educate Canadians about the regimes it administers. The Office monitors the volume of relevant Twitter, news, ​Question Period mentions, and website activity. Tracking these trends can help it prepare for an influx of public and media inquiries, for example, as high volumes tend to lead to workload increases for the Office. Tracking can also make it aware of issues that might relate to its work. The Office publishes this data in its quarterly statistical reports​ as context for the work done in any quarter. Website The Office continued to maintain its website as an important source of information to help educate and inform regulatees, the media and the public. The number of website visitors remained steady with just a 2% increase, for a total of almost 54,000. Social Me​dia The Office’s social media presence helps it stay aware of relevant discussions and participate in them as appropriate. It also uses social media to share information about the conflict of interest regimes it administers, its activities, and the public registry. The Office stayed active on social media in 2022‑2023. It maintained its Twitter presence and, in December 2022, created a LinkedIn account. This gives it another way to educate regulatees and the public and advertise job opportunities. Regulatees are always welcome to contact their advisors if they have any questions. The January 2022 survey of public office holders revealed that only 30% rely on Twitter as a source of information about conflict of interest rules, so the Office shifted its Twitter strategy. It now focuses its tweets on educating its secondary audiences: the media, academics, international and domestic stakeholders, and members of the Canadian public who are interested in the Office’s activities. It sends fewer tweets but aims to send more readers to information on its website. Twitter remains a preferred tool for the media, who are also key stakeholders of the Office. The Office’s tweets can help them report accurately on the Office and its work. The total number of Twitter followers for @EthicsCanada and @EthiqueCanada​ grew by 10% to 3,969, further increasing the Office’s social media reach. It tweeted 7% less than in the previous year, sending one to two tweets a day. Nearly 5% of visits to the Office’s website were from links on Twitter and the Office’s own tweets drove nearly 2% of website traffic. About 45% of the Office website’s traffic resulted from Internet searches. Social media conversations about investigations and ethics matters lead to visits to the Office website to verify facts or get more information. For example, website activity spiked in the week after the Office released the Ng Report. This resulted from the Office’s communications around the report, conversations on social media, and organic searches prompted by media articles. Media and Public Inquiries The Office received nearly 1,800 information requests from the media and members of the public by phone, email, post, fax, and direct messages on Twitter. At the end of May 2022, it received some emails calling on it to investigate parliamentarians’ involvement in the World Economic Forum. Those emails spilled over from a coordinated email campaign that ran earlier in the year. They were prompted by media coverage of the campaign after it was mentioned in the 2021-2022 annual reports. The Communications, Outreach and Planning division responds to media and public inquiries with accurate, timely and useful information. Although it cannot provide information about individual cases, the Office includes as much information as possible about the rules and their general application. The Office responds only to emails that are directly addressed to it and not to ones it is simply copied on. Copies of emails that were not related to its mandate accounted for 80% of total correspondence received in 2022‑2023. The media can help give the public accurate information about the conflict of interest regimes. In 2022‑2023, the Office received and responded to 113 media requests, including 9 interviews, up 20% from the year before. Inquiries about the status of a current case file or public office holder made up 60% of media requests. Only 25% were general inquiries about the role and mandate of the Office. The remaining 15% were related to investigation reports the Office published. Perhaps because of previous interactions with the Office, journalists appear to better understand the regimes, resulting in fewer requests for information about general topics and a more accurate explanation of the regimes administered by the Office. ​ How the Office performed The Office has a set of standards for service to regulatees and others. Its quarterly statistical reports track how it is meeting its service standards, whose achievement rate is set at 80%. In 2022‑2023, the Office again surpassed that target. Service standards 2022-2023Contact all public office holders within three days of learning of their appointment or reappointment93%Respond to public office holders' requests for advice within three business days92%Respond to media inquiries within four hours100%​Respond to public inquiries within 10 business days​92% Note: In the 2021-2022 Annual Report under the Conflict of Interest Code for Members of the House of Commons, achievement of the service standard for responding to requests for advice within three days was listed as 95%; however, the correct figure is 91%. Collaboration and Best Practices The Office maintained and strengthened connections with officials and organizations in Canada and other countries in 2022‑2023. Domestic Outreach CCOIN The Office continued to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN), made up of federal, provincial and territorial conflict of interest commissioners. In 2022‑2023, it added to its electronic library of information and materials from these jurisdictions. It shared summaries of reports on investigations done by CCOIN members. When asked, it also did research for them. The Director of Communications, Outreach and Planning represented former Commissioner Dion at CCOIN’s September 2022 annual meeting, hosted in Yellowknife by David Phillip Jones, K.C., Conflict of Interest Commissioner for the Northwest Territories. The Director also participated in its March 2023 semi-annual meeting, held virtually. Collaboration Former Commissioner Dion met privately with other agents of Parliament to discuss common issues and concerns, and Office employees liaised with their counterparts in those agents’ offices. The Office was asked by the Treasury Board Secretariat to comment on a consultation paper on Public Safety Canada’s Canadian Foreign Influence Transparency (CFIT) initiative. International Outreach The Office is an active member of two international non-profit ethics organizations: the Réseau francophone d’éthique et de déontologie parlementaires (RFEDP) [link in French only] and the Council on Governmental Ethics Laws (COGEL). RFEDP Formed in 2018, the RFEDP is a group of public institutions in the Organisation internationale de la Francophonie that are involved in ethics and codes of conduct. It helps francophone parliamentarians stay connected, shares knowledge, encourages information-sharing, offers training, compares practices, and develops research. In 2022‑2023, the Director of Advisory and Compliance continued to serve on the RFEDP’s Bureau. The Office was part of two RFEDP working groups on training and best practices. The training working group finished its mandate in May 2022. It created a template for training that members can get from its website. The best practices working group was still active at the end of the year. The Office was also working with the RFEDP on a project to partner with universities on research about various topics. In November, former Commissioner Dion participated in the RFEDP’s two-day annual general meeting. The Director of Communications, Outreach and Planning and the Acting Director of Advisory and Compliance also attended. Through the RFEDP, the Office was consulted on several initiatives. In September 2022, it commented on the Interparliamentary Union​’s preliminary indicators aimed at helping parliaments measure their performance in overseeing parliamentary ethics and other areas. In October, it commented on the French version of the Cambodian Senate’s ethics code. COGEL Formed in 1978, COGEL is a U.S.-based organization of government ethics practitioners. The Office’s Director of Communications, Outreach and Planning was a member of the program committee for COGEL’s 2022 conference, held in Montreal in December. Senior Office representatives gave two presentations at the event, which was also attended by several other Office employees. The Director of Communications, Outreach and Planning was on a panel about transparency and one of the Office’s legal counsels was on a panel about blind trusts. The Director is also on the program committee for COGEL’s 2023 conference, to be held in Kansas City, Missouri. Collaboration The Office is always pleased to meet with officials from other countries who wish to discuss Canada’s ethics regimes and share best practices. In February 2023, it gave presentations to delegations from Ethiopia and South Africa. The Office also responded to several information requests from or on behalf of international organizations. In January 2023, it reviewed and commented on the G20 Anti-Corruption Working Group’s High-Level Principles on Promoting Integrity among Public Bodies and Authorities Involved in Preventing and Combating Corruption. It also gave input for Canada’s annual progress report on how it has implemented the Inter-American Convention against Corruption and its Follow-Up Mechanism (MESICIC). In February, the Office commented on a review by South Africa and the United States of how Canada has implemented articles 5-14 and 51-59 of the United Nations Convention against Corruption​ (UNCAC).​ ​Our Tools Our People The Office employs about 50 people. They have expertise in compliance, investigations, legal services, communications, parliamentary relations, and corporate management. Equity, Diversi​​ty and Inclusion The Office recognizes the importance of fostering an engaged, qualified and productive workforce that embraces equity, diversity and inclusion, values differences, and supports the full participation of all employees. The Office continued to work on complying with the Employment Equity Act​. The Act, in part, requires employers to take actions to ensure members of four designated groups are represented within their organizations: women, Indigenous people, persons with disabilities, and members of visible minorities. The Office’s Equity, Diversity and Inclusion Working Group is part of this effort. It includes employees from all divisions. The group led the development of a Policy on Equity, Diversity and Inclusion adopted in October 2022. Under it, a new Equity, Diversity and Inclusion Committee will tackle these objectives: Eliminate systemic barriers to employment and any other conditions that create disadvantages for both employees and prospective candidates.Foster inclusive discussions between employees and inclusive communications with external stakeholders. The Committee made some recommendations that the Office implemented right away. For example, it now writes all job posters in plain language and posts them on boards that will be seen by diverse candidates. It also started working to put other recommendations into practice. Access​ibility The Office is committed to meeting all of its obligations under the Accessible Canada Act. The Act aims to identify, remove, and prevent barriers to accessibility and to make Canada barrier-free by January 1, 2040. In 2022‑2023, the Office ran consultations on accessibility that included surveys. It reflected the feedback in its accessibility plan. That plan shows how the Office identifies and will remove and prevent barriers in its environment, policies, programs, practices, and services. The Office posted its Accessibility Plan 2023-2025​ on its website in December 2022. As an example of how the Office is implementing the plan, it is using accessible formats for its digital communications. It has also started using plain language to help people access, understand, and use the information it shares. Some employees have joined the Government of Canada’s Accessible Communications Community of Practice and its Plain Language Community of Practice. These networks of communications professionals offer excellent learning resources and activities. The Office created a working group on accessibility. It will continue to consult persons with disabilities to identify, remove, and prevent barriers at the workplace and in all aspects of its communications and activities. Internal Communi​cations In 2022‑2023, the Office finished implementing a wide-ranging plan to strengthen internal communications. These are especially important in a hybrid work environment. The strategy also responded to an area that a previous employee satisfaction survey had identified as needing improvement.​ The Office’s Internal Communications Working Group, with employees from all divisions, continued to further improve internal communications. Employee S​​atisfaction Survey In June 2022, the Office conducted an employee satisfaction survey, something it does every three years. The results showed a high level of satisfaction in most areas. Most measures had improved or stayed at the same high level since the last survey in 2019. And almost all of those that had relatively low scores in 2019 went up in 2022. The survey did, however, highlight a few areas that could use some attention. The Office is taking action. St​affing To make sure it has the right positions and the right people in them to carry out its mandate, the Office ran 14 staffing processes in 2022‑2023. Employee turnover rose in 2022‑2023: four employees left.​ Commissioner's Office 4 positions ​ Advisory and Compliance 21 positions Investigations and Legal Services 7 positions Communications, Outreach and Planning 9 positions Corporate Management 11 positions Our Infrastructure The Office continued to update its internal policies and guidelines in line with those of other parliamentary entities and the wider public service. A suite of updated financial policies took effect in 2022‑2023. The Office’s financial statements are audited each year by an independent external auditor. Its financial information for 2022‑2023 is outlined in Appendix A. The Office continued to work with House of Commons IT services on a new, integrated system for compliance. The new system will replace the declaration portal​ that regulatees use to submit information, the public registry and the Office’s internal case management system. It will be a one-stop shop for regulatees, a single point where they can: submit information;keep their contact information up to date;communicate with their advisors;keep track of what they need to do;seek reimbursement of costs associated with blind trust fees and withdrawal from activities. The public registry will be easier to use thanks to a new search interface. There will be no changes to the types of information it contains. This project is complex and challenging. It has used a lot of time and resources and will launch later than originally planned. While delays are unfortunate, it is important to make sure the new system is built right. Because many employees are working in a hybrid format, the Office started reducing its physical space requirements. As of September 2023, it will occupy just one floor instead of two at 66 Slater Street in Ottawa. Our Plan The Office continued to implement a three-year strategic plan covering the 2021-2024 period. The plan is an evergreen tool that helps the Office match its activities to strategic priorities. All projects listed in it are reviewed every quarter. Senior management may adjust some timelines to meet changing operational needs. By March 31, 2023, the Office had completed over two thirds of the projects identified in the plan.​ Appendix Financial Resources Summary (thousands of dollars) Program Activity 2021-2022 2022-2023 ​Alignment toGovernment of CanadaOutcomes​ Actual 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 6,568 7,277 7,277 6,769 Government AffairsContributions to employee benefit plans771866866812 Total spending7,3398,1438,1437,581 Plus: cost of services received without charge1,14100​1,133​Net cost of department8,4808,1438,1438,714 The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on the Office’s effectiveness, management, and operations, together with its operational and expenditure plans. Complete audited financial statements​ are 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 Madam Speaker: I am pleased to submit to you my report on the performance of the Commissioner’s duties and functions under the Conflict of Interest Act in relation to public office holders, for the fiscal year ending March 31, 2023, 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.Interim Conflict of Interest and Ethics Commissioner Dear Mr. Speaker: I am pleased to submit to you the report on the performance of the Commissioner’s duties and functions under the Conflict of Interest Act in relation to public office holders for the fiscal year ending March 31, 2023, 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.Interim Conflict of Interest and Ethics Commissioner Commissioner's Message I am pleased to report on the administration of the Conflict of Interest Act in 2022‑2023. The Office expanded its focus on education and training during the year. Helping public office holders understand the rules helps them avoid conflicts between public and private interests. It also continued to help them comply with the Act and give them confidential advice and direction. Those prevention efforts were balanced by enforcement measures as needed. The Office reported on two investigations under the Act. One was about the conduct of Minister Mary Ng. The other was about the conduct of Parliamentary Secretary Greg Fergus. Contraventions of the Act were found in both cases. It also reported on three referrals from the Public Sector Integrity Commissioner, none of which led to an investigation. The Office carried out its mandate in 2022-2023 through these and other actions. I only came to this role in September 2023, so everything reported here was accomplished under previous leadership. And of course, it rests on the efforts of the Office’s employees. I am honoured to serve Parliament and Canadians and look forward to helping the Office continue its work. The Act and the Conflict of Interest Code for Members of the House of Commons are important accountability tools that help prevent public office from being used for private gain and support transparency. I will bring my experience and judgment to bear in administering them. Our Vision Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament. Our Mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Act​ and the Conflict of Interest Code for Members of the House of Commons.​ Our Stakeholders Regulatees are key stakeholders of the Office. They are the people who are subject to the regimes it administers. Stakeholders also include Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report touches on all stakeholder groups but focuses on the people covered by the Conflict of Interest Act. Public Office Holders Individuals subject to the Act are referred to as public office holders. They must all meet its recusal requirement, its core set of conflict of interest rules and its post-employment rules that apply for life. All public office holders (snapshot as of March 31, 2023) Public office holders2,944Reporting public office holders1,451 - 49%Public office holders without reporting obligations1,493 - 51% Just over half of them (51%) have to follow only those general rules. These “public office holders without reporting obligations” include part-time members of federal boards, commissions and tribunals appointed by the Governor in Council and ministerial staff who work on average less than 15 hours a week. The rest (49%) have to follow some other rules as well. They must confidentially disclose certain information to the Office and publicly declare some information. They are restricted in their outside activities. They are not allowed to hold controlled assets like publicly traded securities. And they face a cooling-off period after leaving public office. These “reporting public office holders” include ministers and parliamentary secretaries, ministerial staff who work on average 15 hours or more a week and people appointed to full-time positions by the Governor in Council.​ Breakdown of reporting pu​blic office holders (Snapshot as of March 31, 2023)​ Public office holders without ​reporting obligations 51% Reporting public office holders 49% Ministerial staff 28% Governor-in-Council appointees 19% Ministers* 1% Parliamentary secretaries* 1% *Also subject to Conflict of Interest Code for Members of the House of Commons At the end of 2022‑2023, 15% more people were subject to the Act than at the end of the year before. The Office’s quarterly statistical reports show how the number of public office holders varied during the year. Turnover among public office holders affects the Office’s workload. For example, when a reporting public office holder is appointed or reappointed, the Office guides them through the initial compliance process. It advises them while they are in office and helps them understand the Act’s post-employment rules when they leave. It also posts their information in the public registry and maintains internal records for them. Turnover in 2022-2023 ​​​​Appointed or reappointed​​Left office​Reporting public office holders331258​Public office holders without reporting obligations​369194 Our Achievements Key activities Reporting to ParliamentReporting to Parliament and testifying before its committees​ComplianceHelping regulatees achieve and maintain compliance with the conflict of interest regimesDirection and adviceGiving regulatees confidential guidance tailored to their individual situationsEducation and outreachHelping regulatees understand their obligations under the regimesEnforcementApplying investigation and other enforcement provisions of the regimes as appropriatePublic communicationsEducating and informing regulatees, the media and the general publicCollaboration and best practicesExchanging information with domestic and international counterparts Reporting to Parliament The Conflict of Interest and Ethics Commissioner has a duty to report to Parliament, testify before parliamentary committees and answer questions from Parliament. The Commissioner reports on behalf of Canadians to Parliament directly, not through a minister. This reflects the Commissioner’s independence as an Officer of the House of Commons. By June 30 each year, the Commissioner must send an annual report on the administration of the Conflict of Interest Act to the Speakers of the House of Commons and Senate for tabling. The Office cannot submit the report in the absence of a Commissioner. The Office sends communiqués to parliamentarians when it issues reports under the Act and the Conflict of Interest Code for Members of the House of Commons. It sent 10 communiqués in 2022‑2023. The House of Commons Standing Committee on Access to Information, Privacy and Ethics has oversight responsibility for the Office. It reviews the Office’s annual spending estimates and matters related to the Commissioner’s reports under the Act. On May 12, 2022, former Commissioner Mario Dion appeared before the Committee to discuss the Office’s 2022‑2023 budget. That appearance was part of the Main Estimates process. Compliance To support its mission to ensure full compliance with the conflict of interest regimes it administers, the Office uses most of its resources to help regulatees follow the rules. Employees in the Advisory and Compliance division help public office holders comply with the Conflict of Interest Act. They give them confidential direction and advice. That guidance is sometimes based on legal opinions prepared by the Investigations and Legal Services division. To meet the Act’s transparency requirements, the Office posts in the public registry some of the information submitted by public office holders. How does the Office help public office holders comply with the Act? By giving them advice when needed2,501 instancesBy posting their public information in the public registry914 postingsBy guiding them through their initial compliance process442 processes The Office aims to contact all public office holders personally within three days of learning of their appointment or reappointment. When are public office holders contacted by the Office? Once a year2,749 reminders / reviewsWhen they are first appointed or reappointed699 communicationsWhen they leave office452 communications Initial compliance process All reporting public office holders must complete an initial compliance process under the Conflict of Interest Act. This means they have to give the Office certain information. When they disclose their information, advisors can help them arrange their affairs to avoid conflicts of interest. Advisors also help them learn the rules. Once they complete the process, it is easier for them to comply with the Act going forward. Public office holders can also ask the Office for advice at any time. Initial compliance is a two-stage process. It must be completed within 120 days after a reporting public office holder’s appointment, or after their reappointment if there is a gap since their last term of office. Reporting public office holders who do not complete these stages on time risk an administrative monetary penalty. The first stage must be completed within 60 days after appointment. This is when the reporting public office holder must submit a Confidential Report to the Office. The second stage must be completed within 120 days after appointment. This is when an advisor in the Office reviews the Confidential Report and discusses it with the reporting public office holder. They also discuss any measures that may be needed to comply with the Act. Examples are divestment of controlled assets, withdrawal from outside activities and conflict of interest screens. The advisor prepares a Summary Statement based on the Confidential Report and any needed public declarations for the reporting public office holder to review, sign and return. Once those items are signed and returned, the initial compliance process is over. The Office then posts the reporting public office holder’s information in the public registry. Initial compliance process for public office holders Helping new reporting public office holders comply with the ActInformingThe Office sends the regulatee an email or a letter telling them about the rules and what they need to do.FilingThey must file a Confidential Report listing things like assets, debt and income within 60 days.ExplainingAn advisor reviews the Confidential Report and calls the regulatee to discuss their file.SigningThe advisor sends them an email or a letter that identifies any extra steps needed and a summary of the Confidential Report for them to sign.FinalizingThe regulatee signs the summary and takes any extra steps required within 120 days of appointment.(442 Initial compliance processes completed)The process is completed when the information is added to the public registry. In 2022‑2023, 83% of reporting public office holders submitted their initial compliance information on time. Of the remaining 17%, more than half submitted their information within one week of the deadline. Deadlines may be missed if the Office is not notified of new appointments right away or if complex measures are needed to complete the file. The number of initial compliance processes completed does not always match the number of summary statements posted in the public registry in a given fiscal year. That is because some processes may have been completed in one fiscal year and the statements posted in the next. Divestment Reporting public office holders must divest any controlled assets they have. They can sell them in an arm’s-length transaction (to someone other than a relative, friend or business associate). Or they can place them in a blind trust. Under subsection 27(10) of the Act, the Commissioner can grant an exception to this rule in certain cases. The reporting public office holder must not be a minister or parliamentary secretary. And their total investments in controlled assets must be of such minimal value they do not constitute any risk of conflict of interest in relation to their official duties and functions. For the Office to consider an exception, the value of the controlled assets must be less than $30,000. In 2022‑2023, there were 50 divestments of controlled assets, including 38 by sale and 12 by blind trust. The Office issues reimbursement orders to reporting public officer holders’ organizations for reasonable costs of setting up, maintaining and dismantling blind trusts. The Corporate Management division reviews and analyzes those costs, as well as withdrawal and commission fees. This helps the Commissioner decide if the costs are reasonable so reimbursement orders may be issued. In 2022‑2023, 153 orders for reimbursement were issued, totalling just under $775,000, down 27% from $1 million the previous year. There were fewer reimbursement orders for setting up blind trusts than the year before. In 2022‑2023, the Office raised the maximum annual rates for reimbursing certain administrative costs for blind trusts. The new rates are listed in an updated information notice. They apply to billing periods ending on or after January 1, 2023.​ 2022-20232021-2022Initial compliance processes completed442352Divestments of controlled assets by sale3829Divestments of controlled assets by blind trust1224 Public office holders without reporting obligations do not have to complete an initial compliance process. After they are appointed, the Office sends them a letter with a copy of the Act and a summary of the rules they need to follow. When the end of their term is coming up, the Office sends them a post-employment letter. The Office also communicates with those public office holders while they are in office. In 2022‑2023, for example, it sent them links to investigation reports and to the 2021-2022 Annual Report under the Act and invited them to four educational sessions. Ongoing Reporting Requirements After completing the initial compliance process, reporting public office holders must meet various reporting requirements throughout their time in office to stay in compliance with the Conflict of Interest Act. For example, they must let the Office know about any change to the information in their Confidential Report, within 30 days of the change. This is very important because changes to their personal situation (called “material changes”) could create the potential for conflicts of interest. Material changes could include buying or selling a house or a car, getting or paying off a loan, and any new ties between their relatives or friends and government entities. Disclosing this kind of information to the Office can help prevent conflicts of interest. It allows the Office to advise reporting public office holders of anything they must do. This could include submitting a new public declaration or amending an existing one.​ Ongoing reporting requirements Annual review Just under 1,300 annual reviews initiated and 1,100 receivedMaterial changes Gifts or other advantages Private flights accepted by ministers and parliamentary secretaries for themselves, their families or ministerial staff Recusals Firm offers of outside employment and their acceptance Over 75 firm offers and acceptances disclosed Survey of Public Office Holders The Office continued to use the results of its January 2022 survey of public office holders—the first such survey since the Conflict of Interest Act took effect in 2007—to improve service delivery. To support transparency, in November 2022 it released detailed survey results. Key takeaways: Most of those who responded believe the Office is a credible (80%), impartial (76%), helpful (73%), and trustworthy (81%) organization.The overwhelming majority (97%) said they were familiar with their obligations under the Act.Most (84%) who had recently interacted one-on-one with an Office employee were satisfied with their experience and thought the employee was courteous and helpful (91%), provided a timely and accurate response (89%) and gave them the information they needed (86%).Most said personal interactions are the Office’s top value-add.When asked about preferred training methods, most said they prefer online training with a live presenter. The full survey is attached to this report as Appendix B. End of Mandate and Post-Employment Some rules in the Conflict of Interest Act apply to public office holders who might be considering other jobs. Others apply to all public office holders after they leave public office. While in office, public office holders must not let themselves be influenced by plans for, or offers of, outside employment. Reporting public office holders must let the Office know about all firm offers of outside employment within seven calendar days after receiving them. If a reporting public office holder is considering accepting an offer, their advisor can tell them if they can accept it given their obligations under the Act. If they accept an offer of outside employment, they must disclose the acceptance in writing to the Office, and to other authorities listed in the Act, within seven calendar days. Their advisor will then give them additional guidance on their current and post-employment obligations. Some of the Act’s post-employment rules​ apply to all former public office holders indefinitely. Others apply to former reporting public office holders for a cooling-off period of one or two years. Former reporting public office holders do not have to report any new jobs they accept. However, they are encouraged to consult the Office to make sure they meet their post-employment obligations. The Office monitors sources of public information about their employment activities after leaving public office. It does this to ensure they meet the Act’s post-employment rules and to check that those activities match the information they gave the Office when entering post-employment. In 2022‑2023, almost 250 individuals were still subject to a cooling-off period. This is a 40% decrease from the year before.​ Public Registry The Office maintains a public registry of all information about individual regulatees that the Commissioner is authorized to make public. It is a searchable database that is often accessed by regulatees, the media, members of the public, governments, and ethics practitioners around the world. In 2022‑2023, the Office posted almost 1,400 items for all regulatees in the public registry, up 10% from the year before. There were over 80,500 public registry page views in 2022‑2023, almost a third more than the year before. In the past few years, there has been an overall increase in the number of public registry visits, with significant spikes in the first and last quarters of 2022‑2023. To promote transparency, the Office has drawn attention to the public registry in its public communications. This continued increase in the number of visits reflects greater interest in and knowledge of the Office’s mandate and the regimes it administers. What did public office holders declare? 2022-20232021-2022Agreed compliance measures2525Assets104139Gifts or other advantages16741Liabilities2282Outside activities154​120Recusals3321Summary statements370322Travel*93Other1613 *Ministers and parliamentary secretaries only Direction and Advice Prevention is a major focus of the Conflict of Interest Act. Public office holders must learn the rules so they can recognize possible conflicts of interest and take steps to avoid them. The Office guides public office holders proactively, giving them direction on issues that involve real or potential conflicts of interest. It also encourages them to consult the Office if they have questions or concerns. Advisors give them advice based on the facts at hand, with input from the Commissioner as needed. The Commissioner personally reviews all advice for certain reporting public office holders. These include ministers, parliamentary secretaries, some heads of agencies, deputy ministers and chiefs of staff to ministers. When asked, the Office also offers advice about the Act’s requirements to people who are considering a public office holder position. In 2022‑2023, the Office responded to over 2,500 requests for advice from public office holders, down 25% from the year before. Several factors may account for this drop. For example, there were fewer requests for advice about post-employment obligations as there was an election the previous year that resulted in more turnover. The Office also targeted its educational sessions to public office holders to give them timely information about the Act. It received 18% fewer requests for advice about general obligations, likely because questions about them were answered during those sessions. Requests for advice about gifts and other advantages more than tripled from the year before. There were 167 public declarations of gifts, including event invitations, four times more than in the year before. This may be in part because there were more in-person events than earlier in the pandemic. The Office makes sure the confidential advice it gives public office holders is clear and consistent. Advice reflects their personal circumstances, so different advice may be given in cases that appear similar. The Office ensures consistency by recording the Commissioner’s interpretations of the Act in an internal practice manual that advisors can consult, and by adding public office holders’ requests for advice to their files. The Office tracks the types of advice requested so it can spot trends that may impact its workload and identify training needs. It has noted that some activities prompt regulatees to ask for advice or disclose certain information. For example, in November 2022, the Office organized an educational session on reporting obligations. In the next quarter, the number of gifts or other advantages and recusals reported to the Office rose 22%. The Office’s quarterly statistical reports track changes in the volume of requests for advice and types of advice requested. By monitoring and analyzing trends, the Office can anticipate and meet regulatees’ information needs. What did public office holders ask about by quarter? Q1Q2 Q3 Q4 2022-2023 Gifts and other advantages10781104117409Outside activities82706393308Post-employment obligations103928585365Material changes172169174240755General obligations151128166219664 Education and Outreach Public office holders are key stakeholders of the Office. One of its strategic objectives is to increase the trust key stakeholders have in the Office and the Office’s credibility in their eyes. The idea is for them to become stronger allies in the delivery of its mandate and to be able to effectively manage conflict of interest issues. In 2022‑2023, the Office started implementing a strategic communications and engagement plan to help achieve that objective. The plan includes ways to better understand the needs of the Office’s audiences so it can make its communications and outreach activities more effective. Regulatees, including public office holders, are its primary target audience so the Office reaches them in different ways than the media, academics, domestic and international stakeholders, and others. Actions in the plan help the Office give public office holders the information they need, when they need it, and in the way they want to receive it. In the past three years, the Office revamped its training materials, tested different technologies, and researched new ways to deliver educational sessions to regulatees. It also analyzed the results of the 2022 survey of public office holders to see if their roles affected their training needs and preferences. The result of all this research and testing was a plan for delivering educational sessions on a regular basis and in a purposeful way. In 2022‑2023, the Office started regularly inviting public office holders to educational sessions geared to their particular status and where they are in their mandate. TopicAudienceObligationsReporting public office holders appointed in the last 60 daysObligationsPublic office holders without reporting obligations who were appointed in the last 120 daysReporting requirementsReporting public office holders whose annual reviews were coming upPost-employmentReporting public office holders working for tribunals, boards and commissions The Office collected feedback on these sessions to continuously improve its education and outreach program. It engaged with the Privy Council Office so more public office holders could attend its educational sessions. This cooperation means potential Governor in Council appointees can be included in the sessions for new reporting public office holders. It also encourages attendance by helping make new regulatees aware of the sessions. The Office gave 23 educational presentations to ministers’ offices and organizations with public office holders. It offered 14 of these proactively and the rest when asked by regulatees or their organizations. The ministers’ offices were Canadian Heritage, and International Trade, Export Promotion, Small Business and Economic Development. Most of these educational activities were online, allowing more regulatees to attend, and letting participants ask questions anonymously. Online training is also cost-effective. The Office reached over 300 regulatees through educational sessions and presentations in 2022‑2023, fewer than the year before. This is because it invited fewer public office holders. It reached out to individual public office holders at specific points during their mandate so the sessions would be more useful to them. The Office wrote an op-ed that was published in The Hill Times in August 2022. The article explained why ministerial staff must follow different conflict of interest rules than Members of the House of Commons’ staff and what those rules are. The Hill Times is a key news source for ministerial staff and others who work on Parliament Hill, so this was a good opportunity for the Office to reach some of its key stakeholders. The Office also conducts activities that may help educate future public office holders or ethics practitioners. For example, in January 2023 the Director of Communications, Outreach and Planning gave a presentation to a class at Carleton University. Lobbying Commissioner, Nancy Bélanger, also participated. The Office has a Memorandum of Understanding with the Commissioner of Lobbying for joint educational activities. Enforcement The Office seeks to ensure full compliance with the Conflict of Interest Act. However, it can also use the Act’s enforcement mechanisms to address non-compliance. Administrat​ive Monetary Penalties Under sections 52 and 53 of the Act, the Commissioner can impose administrative monetary penalties of up to $500 for not meeting certain reporting requirements within set deadlines. When a penalty is issued, the Commissioner must make public the nature of the violation, the name of the public office holder and the amount of the penalty. The Office posts penalties in the public registry. It may also publish them on social media to support openness and transparency and encourage compliance. Administrative monetary penalties 2022-202382021-202218 Compliance Orders Under section 30 of the Act, the Commissioner may order a public office holder to take any measure to comply with it. Compliance measures include submitting documents for their annual review, divesting controlled assets or ceasing prohibited activities. Like administrative monetary penalties, compliance orders are posted in the public registry and may be shared on social media.​ Compliance orders 2022-202342021-202215 Examinations Investigations under the Act are called “examinations.” Under section 44 of the Act, the Commissioner can investigate a possible contravention at the request of a Senator or Member of the House of Commons who provides reasonable grounds to believe the Act has been contravened. The Office received two examination requests from Members in 2022‑2023. Under section 45 of the Act, the Commissioner may self-initiate an examination if the Commissioner has reason to believe a current or former public office holder has contravened the Act. A decision to investigate may result from information from media reports or complaints from members of the public, among other sources. The Office received eight examination requests from members of the public in 2022‑2023. The Commissioner issues a public report when an examination is completed. When the Commissioner decides to discontinue an examination launched under section 44​ of the Act, a discontinuance report is issued. However, when an examination launched under section 45 is discontinued, the Commissioner decides whether to issue a report. The Commissioner reports on examinations under the Act to the Prime Minister. In 2022‑2023, the Office issued two examination reports under the Act. Fergus Report The Fergus Report, issued on February 14, 2023, focused the conduct of the Honourable Greg Fergus, Parliamentary Secretary to the Prime Minister and to the President of the Treasury Board, and Member of Parliament for Hull–Aylmer. Former Commissioner Dion found Mr. Fergus contravened section 9 the Act when he wrote a letter supporting a television network’s application for a broadcasting licence that was before the Canadian Radio-television and Telecommunications Commission (CRTC). Section 9 prohibits public office holders from using their position to seek to influence a decision of another person so as to improperly further another person’s private interests. The Commissioner found the letter of support was intended to influence a CRTC decision in order to further the network’s private interests. The Commissioner further determined that Mr. Fergus sought to improperly further those private interests because he did not follow the practice established for parliamentary secretaries in dealing with administrative tribunals like the CRTC. Even though Mr. Fergus signed the letter as a Member of Parliament and did not use his Parliamentary Secretary title, the Office had previously established, in compliance orders, in The Gill Report​ and in an information notice, that ministers and parliamentary secretaries should not write letters of support to quasi-judicial tribunals like the CRTC, given their governmental roles and the influence they have. The role of parliamentary secretaries and the principle of non-intervention in quasi-judicial decisions are also outlined in the Prime Minister’s Open and Accountable Government guide​. Ng Report The Ng Report, issued on December 13, 2022, was about the conduct of the Honourable Mary Ng, Minister of International Trade, Export Promotion, Small Business and Economic Development. The examination focused on whether Minister Ng had contravened subsection 6(1), section 9 or section 21 of the Act by participating in the process that led to the awarding of two government contracts to a company owned by a friend. Subsection 6(1) prohibits public office holders from making a decision that would place them in a conflict of interest. As described in section 4​, they are in a conflict of interest when they exercise an official power, duty or function that provides an opportunity to further their private interests or those of their relatives or friends or to improperly further another person’s private interests. Section 9 prohibits public office holders from using their 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 their relatives or friends or to improperly further another person’s private interests. Section 21 requires public office holders to recuse themselves from any discussion, decision, debate or vote on any matter in respect of which they would be in a conflict of interest. In March 2019 and April 2020, contracts for media training services were signed on behalf of the Minister with a company co-founded and run by Ms. Amanda Alvaro. Former Commissioner Dion determined that Ms. Ng and Ms. Alvaro were friends within the meaning of the Act and that Ms. Ng was exercising an official power, duty or function when she participated in the process that led to the awarding of the contracts to her friend’s company. Given their friendship, obtaining services from the company improperly furthered its interests and placed Ms. Ng in a conflict of interest as defined by the Act, in contravention of subsection 6(1). The Commissioner found that Ms. Ng also contravened section 21 of the Act by failing to recuse herself from the contract decisions. She should have known to instead withdraw from the process that led to the awarding of the contracts and obtain similar services from another provider. Having determined that Ms. Ng was involved in the process that led to the awarding of the contracts, there was no need to examine the issue of her influence over the decisions to award those contracts under section 9 of the Act. Referrals from the Public Sector Integrity Commissioner Matters may be referred to the Commissioner by the Public Sector Integrity Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act​. This provision also gives Canadians another way to make the Commissioner aware of possible issues. The Commissioner is required, by section 68 of the Conflict of Interest Act, to issue a public report on each referral, whether or not an examination is launched. In 2022‑2023, the Office issued three reports on referrals from the Public Sector Integrity Commissioner. None resulted in an examination as former Commissioner Dion found no reason to believe in any of the cases that the Conflict of Interest Act may have been contravened. Scott Report The Scott Report​, issued on August 24, 2022, concerned an allegation of conflict of interest against Mr. Ian Scott, then Chairperson and Chief Executive Officer of the Canadian Radio-television and Telecommunications Commission (CRTC). It dealt with apparent conflicts of interest and the definition of friendship within the meaning of the Act. It was alleged that Mr. Scott had several meetings with large telecommunication providers while they had files before the CRTC, thereby failing to avoid apparent conflicts of interest. However, apparent conflicts of interest are not captured by the prohibitions in the Act. One of the meetings was with a senior BCE Inc. and Bell Canada executive who was described, in a media article, as a friend of Mr. Scott’s. The week before, Bell Canada had asked the CRTC to review and vary an August 2019 Telecom Order. Mr. Scott was on the CRTC panel that issued a May 2021 Telecom Decision varying the order. Former Commissioner Dion was concerned that, by participating in that decision, Mr. Scott may have had an opportunity to further the private interests of a friend or to improperly further those of a corporation run by a friend. This would contravene subsection 6(1) of the Act, which prohibits a public office holder from making any decision or participating in the making of a decision that furthers their private interests or those of their relatives or friends, or that improperly furthers the private interests of another person. After reviewing additional information, however, the Commissioner was satisfied that Mr. Scott and the executive’s relationship could not be considered one of friendship within the meaning of the Act. Report on alleged wrongdoing by the head of a federal organization The Report on alleged wrongdoing by the head of a federal organization, issued on January 24, 2023, concerned an allegation against the head of a federal organization. The individual allegedly placed themselves in a conflict of interest by engaging in activities involving their previous employer in the context of their public duties, and appeared to give favourable treatment to a topic that is their field of expertise. As outlined in the report, the referral by the Public Sector Integrity Commissioner serves as a reminder to all public office holders to ensure they are familiar with the rules on outside activities in section 15 of the Act. Report on alleged wrongdoing by a public office holder The Report on alleged wrongdoing by a public office holder, issued on December 1, 2022, concerned allegations of conflict of interest against a public officer holder. When the allegations were made, the individual held an executive position with a federal agency and had previously held public office with a different federal agency. The individual allegedly used their public office to further their private interests or to improperly further the interests of a private company in which they had private interests. In fact, they had no private interests in the company and did not use their public office to improperly further its interests. Barring exceptional circumstances, the Office’s target is to conduct examinations within 12 months. In 2022‑2023, the average time to complete an examination or review a referral from the Public Sector Integrity Commissioner was just over five months. As of March 31, 2023, the Office was not working on any examinations under the Act.​ Case Files under the Act When the Office receives information about a possible contravention of the Act, whether from a Senator or Member of the House of Commons, media reports, or complaints from members of the public, it may open a case file. When a case file is opened, the Office conducts an initial review of the matter. Some of these reviews may lead to examinations. When an examination is not found to be warranted, the case file is closed. Case files under the Act in 2022-2023 How many case files were opened and closed?​Total case files (a case file is a concern that is reviewed by the Office)​20Ongoing1Closed without an examination14Closed with publication of report5Who was the subject of each case file?*​Current or former minister or parliamentary secretary6Current or former public office holder14Person not subject to the Act0What was the source of these case files?Member of the general public8Within the Office1Member of the House of Commons2Media6Office of the Public Sector Integrity Commissioner6What was the nature of the concern?*​Furthering a private interest10Duty to recuse3​Post-employment rules1Influence7​Preferential treatment2​​Private air travel0​Prohibited activities​2Public declaration1​Insider information​0​Gifts and other advantages0​Material c​hanges0​ ​​​*Some case files have more than one subject or concern Court M​atters Matters involving investigations are sometimes the object of applications for judicial review. While dealing with these can use a lot of resources, they can also help clarify the Commissioner’s mandate and powers. Democracy Watch filed an application for judicial review to the Federal Court of Appeal about former Commissioner Dion’s findings in the 2021 Trudeau III Report. In this report, the Commissioner had concluded that Prime Minister Justin Trudeau’s involvement in awarding the administration of a COVID-19-related program to WE Charity did not contravene the Act, even though several members of Mr. Trudeau’s family were closely involved in some of WE Charity’s initiatives. The Commissioner determined that the scope of the Act was limited to real or potential conflicts of interest, and the mere existence of an apparent conflict was insufficient to result in a contravention of the Act. In its Notice of Application, Democracy Watch raised alleged errors of law and of 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 the Commissioner’s finding that Mr. Trudeau was not friends with WE Charity’s co-founders was incorrect. As part of its Notice of Application, Democracy Watch also requested a certified copy of all the relevant materials the Commissioner looked at during the examination (called the “certified tribunal record”). The Commissioner objected to the request for the certified tribunal record on the basis that the Act’s privative clause, section 66, does not allow the types of grounds for review that Democracy Watch raised in its Notice of Application. In a motion to strike the Notice of Application, the Attorney General of Canada, who is the respondent in the case before the Federal Court of Appeal, also wrote that section 66 does not allow the Court to review the alleged errors of law and fact. The judge who heard the Attorney General’s motion to strike decided that the full panel hearing the merits of Democracy Watch’s application should examine the question relating to section 66, because the full panel—not a single judge—needs to clarify the important issue of how privative clauses should be interpreted and applied (Democracy Watch v. Canada [Attorney General], 2022 FCA 208). Democracy Watch filed a specific motion to obtain the certified tribunal record. The Commissioner maintained the objection, noting that much of the material was confidential. In a second decision, the judge wrote that the Commissioner should not be required to disclose confidential documents in support of a ground that the Court might not be allowed to review because of section 66 (Democracy Watch v. Canada [Attorney General], 2023 FCA 39). The judge decided that the Court should therefore proceed in two stages. In stage 1, the full panel of the Court will determine how section 66 of the Act applies to the matter. If the Court determines that section 66 applies, it may dismiss Democracy Watch’s application. Otherwise, if it determines that some or all of the grounds are allowed, it may move on to stage 2 and review the application on its merits. As of March 31, 2023, a hearing date for stage 1 had not been set. Public Communications​​ The Office shares information on its website, is active on social media, responds to inquiries from the media and members of the public, and delivers presentations to the interested public. The goal is to educate Canadians about the regimes it administers. The Office monitors the volume of relevant Twitter, news, and Question Period mentions and website activity. Tracking these trends can help it prepare for an influx of public and media inquiries, for example, as high volumes tend to lead to workload increases for the Office. Tracking can also make it aware of issues that might relate to its work. The Office publishes this data in its quarterly statistical reports as context for the work done in any quarter.​ Website The Office continued to maintain its website as an important source of information to help educate and inform regulatees, the media and the public. The number of website visitors remained steady with just a 2% increase, for a total of almost 54,000. Social Me​dia The Office’s social media presence helps it stay aware of relevant discussions and participate in them as appropriate. It also uses social media to share information about the conflict of interest regimes it administers, its activities, and the public registry. The Office stayed active on social media in 2022‑2023. It maintained its Twitter presence and, in December 2022, created a LinkedIn account. This gives it another way to educate regulatees and the public and advertise job opportunities. Regulatees are always welcome to contact their advisors if they have any questions. The January 2022 survey of public office holders revealed that only 30% rely on Twitter as a source of information about conflict of interest rules, so the Office shifted its Twitter strategy. It now focuses its tweets on educating its secondary audiences: the media, academics, international and domestic stakeholders, and members of the Canadian public who are interested in the Office’s activities. It sends fewer tweets but aims to send more readers to information on its website. Twitter remains a preferred tool for the media, who are also key stakeholders of the Office. The Office’s tweets can help them report accurately on the Office and its work. The total number of Twitter followers for @EthicsCanada and @EthiqueCanada​ grew by 10% to 3,969, further increasing the Office’s social media reach. It tweeted 7% less than in the previous year, sending one to two tweets a day. Nearly 5% of visits to the Office’s website were from links on Twitter and the Office’s own tweets drove nearly 2% of website traffic. About 45% of the Office website’s traffic resulted from Internet searches. Social media conversations about investigations and ethics matters lead to visits to the Office website to verify facts or get more information. For example, website activity spiked in the week after the Office released the Ng Report. This resulted from the Office’s communications around the report, conversations on social media, and organic searches prompted by media articles. Media and Public Inquiries The Office received nearly 1,800 information requests from the media and members of the public by phone, email, post, fax, and direct messages on Twitter. At the end of May 2022, it received some emails calling on it to investigate parliamentarians’ involvement in the World Economic Forum. Those emails spilled over from a coordinated email campaign that ran earlier in the year. They were prompted by media coverage of the campaign after it was mentioned in the 2021-2022 annual reports. The Communications, Outreach and Planning division responds to media and public inquiries with accurate, timely and useful information. Although it cannot provide information about individual cases, the Office includes as much information as possible about the rules and their general application. The Office responds only to emails that are directly addressed to it and not to ones it is simply copied on. Copies of emails that were not related to its mandate accounted for 80% of total correspondence received in 2022‑2023. The media can help give the public accurate information about the conflict of interest regimes. In 2022‑2023, the Office received and responded to 113 media requests, including 9 interviews, up 20% from the year before. Inquiries about the status of a current case file or public office holder made up 60% of media requests. Only 25% were general inquiries about the role and mandate of the Office. The remaining 15% were related to investigation reports the Office published. Perhaps because of ​previous interactions with the Office, journalists appear to better understand the regimes, resulting in fewer requests for information about general topics and a more accurate explanation of the regimes administered by the Office. ​ How the Office performed​ The Office has a set of standards for​ service to regulatees and others. Its quarterly statistical reports​ track how it is meeting its service standards, whose achievement rate is set at 80%. In 2022‑2023, the Office again surpassed that target. Service standards ​​​ ​​2022​-2023Contact all public office holders within three days of learning of their appointment or reappointment93%Respond to public office holders' requests for advice within three business days92%Respond to media inquiries within four hours100%​Respond to public inquiries within 10 business days​92% Collaboration and Best Practices​ The Office maintained and strengthened connections with officials and organizations in Canada and other countries in 2022‑2023. Domestic Outreach CCOIN The Office continued to coordinate information sharing within the Canadian Conflict of Interest Network (CCOIN), made up of federal, provincial and territorial conflict of interest commissioners. In 2022‑2023, it added to its electronic library of information and materials from these jurisdictions. It shared summaries of reports on investigations done by CCOIN members. When asked, it also did research for them. The Director of Communications, Outreach and Planning represented former Commissioner Dion at CCOIN’s September 2022 annual meeting, hosted in Yellowknife by David Phillip Jones, K.C., Conflict of Interest Commissioner for the Northwest Territories. The Director also participated in its March 2023 semi-annual meeting, held virtually. Collaboration Former Commissioner Dion met privately with other agents of Parliament to discuss common issues and concerns, and Office employees liaised with their counterparts in those agents’ offices. The Office was asked by the Treasury Board Secretariat to comment on a consultation paper on Public Safety Canada’s Canadian Foreign Influence Transparency (CFIT) initiative. International Outreach The Office is an active member of two international non-profit ethics organizations: the Réseau francophone d’éthique et de déontologie parlementaires (RFEDP) [link in French only] and the Council on Governmental Ethics Laws (COGEL). RFEDP Formed in 2018, the RFEDP is a group of public institutions in the Organisation internationale de la Francophonie that are involved in ethics and codes of conduct. It helps francophone parliamentarians stay connected, shares knowledge, encourages information-sharing, offers training, compares practices, and develops research. In 2022‑2023, the Director of Advisory and Compliance continued to serve on the RFEDP’s Bureau. The Office was part of two RFEDP working groups on training and best practices. The training working group finished its mandate in May 2022. It created a template for training that members can get from its website. The best practices working group was still active at the end of the year. The Office was also working with the RFEDP on a project to partner with universities on research about various topics. In November, former Commissioner Dion participated in the RFEDP’s two-day annual general meeting. The Director of Communications, Outreach and Planning and the Acting Director of Advisory and Compliance also attended. Through the RFEDP, the Office was consulted on several initiatives. In September 2022, it commented on the Interparliamentary Union’s preliminary indicators aimed at helping parliaments measure their performance in overseeing parliamentary ethics and other areas. In October, it commented on the French version of the Cambodian Senate’s ethics code. COGEL Formed in 1978, COGEL is a U.S.-based organization of government ethics practitioners. The Office’s Director of Communications, Outreach and Planning was a member of the program committee for COGEL’s 2022 conference, held in Montreal in December. Senior Office representatives gave two presentations at the event, which was also attended by several other Office employees. The Director of Communications, Outreach and Planning was on a panel about transparency and one of the Office’s legal counsels was on a panel about blind trusts. The Director is also on the program committee for COGEL’s 2023 conference, to be held in Kansas City, Missouri. Collaboration The Office is always pleased to meet with officials from other countries who wish to discuss Canada’s ethics regimes and share best practices. In February 2023, it gave presentations to delegations from Ethiopia and South Africa. The Office also responded to several information requests from or on behalf of international organizations. In January 2023, it reviewed and commented on the G20 Anti-Corruption Working Group’s High-Level Principles on Promoting Integrity among Public Bodies and Authorities Involved in Preventing and Combating Corruption. It also gave input for Canada’s annual progress report on how it has implemented the Inter-American Convention against Corruption and its Follow-Up Mechanism (MESICIC). In February, the Office commented on a review by South Africa and the United States of how Canada has implemented articles 5-14 and 51-59 of the United Nations Convention against Corruption​ (UNCAC).​ ​Our Tools Our People The Office employs about 50 people. They have expertise in compliance, investigations, legal services, communications, parliamentary relations, and corporate management. Equity, Diversi​​ty and Inclusion The Office recognizes the importance of fostering an engaged, qualified and productive workforce that embraces equity, diversity and inclusion, values differences, and supports the full participation of all employees. The Office continued to work on complying with the Employment Equity Act​. The Act, in part, requires employers to take actions to ensure members of four designated groups are represented within their organizations: women, Indigenous people, persons with disabilities, and members of visible minorities. The Office’s Equity, Diversity and Inclusion Working Group is part of this effort. It includes employees from all divisions. The group led the development of a Policy on Equity, Diversity and Inclusion adopted in October 2022. Under it, a new Equity, Diversity and Inclusion Committee will tackle these objectives: Eliminate systemic barriers to employment and any other conditions that create disadvantages for both employees and prospective candidates.Foster inclusive discussions between employees and inclusive communications with external stakeholders. The Committee made some recommendations that the Office implemented right away. For example, it now writes all job posters in plain language and posts them on boards that will be seen by diverse candidates. It also started working to put other recommendations into practice. Accessibility The Office is committed to meeting all of its obligations under the Accessible Canada Act. The Act aims to identify, remove, and prevent barriers to accessibility and to make Canada barrier-free by January 1, 2040. In 2022‑2023, the Office ran consultations on accessibility that included surveys. It reflected the feedback in its accessibility plan. That plan shows how the Office identifies and will remove and prevent barriers in its environment, policies, programs, practices, and services. The Office posted its Accessibility Plan 2023-2025 on its website in December 2022. As an example of how the Office is implementing the plan, it is using accessible formats for its digital communications. It has also started using plain language to help people access, understand, and use the information it shares. Some employees have joined the Government of Canada’s Accessible Communications Community of Practice and its Plain Language Community of Practice. These networks of communications professionals offer excellent learning resources and activities. The Office created a working group on accessibility. It will continue to consult persons with disabilities to identify, remove, and prevent barriers at the workplace and in all aspects of its communications and activities. Internal Communi​cations In 2022‑2023, the Office finished implementing a wide-ranging plan to strengthen internal communications. These are especially important in a hybrid work environment. The strategy also responded to an area that a previous employee satisfaction survey had identified as needing improvement.​ The Office’s Internal Communications Working Group, with employees from all divisions, continued to further improve internal communications. Employee S​​atisfaction Survey In June 2022, the Office conducted an employee satisfaction survey, something it does every three years. The results showed a high level of satisfaction in most areas. Most measures had improved or stayed at the same high level since the last survey in 2019. And almost all of those that had relatively low scores in 2019 went up in 2022. The survey did, however, highlight a few areas that could use some attention. The Office is taking action. St​affing To make sure it has the right positions and the right people in them to carry out its mandate, the Office ran 14 staffing processes in 2022‑2023. Employee turnover rose in 2022‑2023: four employees left.​ ​ Commissioner's Office ​4 positions ​ ​ Advisory and Compliance 21 positions Investigations and Legal Services 7 positions Communications, Outreach and Planning 9 positions Corporate Management 11 positions Our Infrastructure The Office continued to update its internal policies and guidelines in line with those of other parliamentary entities and the wider public service. A suite of updated financial policies took effect in 2022‑2023. The Office’s financial statements are audited each year by an independent external auditor. Its financial information for 2022‑2023 is outlined in Appendix A. The Office continued to work with House of Commons IT services on a new, integrated system for compliance. The new system will replace the disclosure portal​ that regulatees use to submit information, the public registry and the Office’s internal case management system. It will be a one-stop shop for regulatees, a single point where they can: submit information;keep their contact information up to date;communicate with their advisors;keep track of what they need to do;seek reimbursement of costs associated with blind trust fees and withdrawal from activities. The public registry will be easier to use thanks to a new search interface. There will be no changes to the types of information it contains. This project is complex and challenging. It has used a lot of time and resources and will launch later than originally planned. While delays are unfortunate, it is important to make sure the new system is built right. Because many employees are working in a hybrid format, the Office started reducing its physical space requirements. As of September 2023, it will occupy just one floor instead of two at 66 Slater Street in Ottawa. Our Plan The Office continued to implement a three-year strategic plan covering the 2021-2024 period. The plan is an evergreen tool that helps the Office match its activities to strategic priorities. All projects listed in it are reviewed every quarter. Senior management may adjust some timelines to meet changing operational needs. By March 31, 2023, the Office had completed over two thirds of the projects identified in the plan.​ Appendix A Financial Resources Summary ​(thousands of dollars) Program Activity ​2021-2022​ 2022-2023 ​Alignment toGovernment of CanadaOutcomes Actual 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 6,568 7,277 7,277 6,769 ​Government AffairsContributions to employee benefit plans771866866812​Total spending7,3398,1438,1437,581 Plus: cost of services received without charge1,141001,133​Net cost of department8,4808,1438,1438,714 The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on the Office’s effectiveness, management, and operations, together with its operational and expenditure plans. Complete audited financial statements​ are available on the Office’s website.​ Appendix B ​Public office holder survey report​

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 Mr. Speaker: I am pleased to submit to you my rep​ort on the performance of my duties and functions under the Conflict of Interest Act in relation to public office holders for the fiscal year ending March 31, 2022, for tabling in the Senate. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Mario DionConflict of Interest and Ethics Commissioner Dear Mr. Speaker: I am pleased to submit to you my 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, 2022, 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, Mario DionConflict of Interest and Ethics Commissioner Commissioner's message I am pleased to report on the administration of the Conflict of Interest Act in 2021-2022. Throughout the year, the Office helped public office holders achieve and maintain compliance with the Act, gave them confidential guidance tailored to their individual situations, and helped them understand their obligations. After the September 2021 election, we helped ministers, parliamentary secretaries and ministerial staff complete the initial compliance process under the Act. Prevention is the major focus of the regimes the Office administers, and in the past year we strengthened education initiatives to help prevent conflicts of interest. The Office supports, advises and directs public office holders, and monitors their actions. However, it is up to all public office holders to take the time to learn about the conflict of interest rules and develop a reflex to act ethically. In the area of enforcement, we reported on two examinations under the Act. One concerned the conduct of Prime Minister Justin Trudeau in relation to the selection of the WE organization as the administrator of the Canada Student Service Grant. The other concerned the conduct of former Finance Minister Bill Morneau regarding the same matter. We were also busy in other key activity areas. The volume of compliance work with regulatees increased by over 40% compared to the previous year. The Office supported transparency by maintaining the public registry and publishing quarterly statistical reports on its activities. We educated and informed Canadians about the conflict of interest regimes and the Office's work. We further grew the Office's social media presence. We also continued to work with our Canadian and international counterparts. I passed the mid-point of my seven-year term as Commissioner in 2021-2022. This was an opportune time to take stock of the processes and procedures that are in place to support the achievement of our mission. The Office has evolved into a mature organization, and I believe our approach to compliance assurance has proven effective and efficient. I remain honoured to serve Parliament and Canadians and am grateful to the employees of the Office for helping me fulfill my mandate. Our vision Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament. Our mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Act​ and the Conflict of Interest Code for Members of the House of Commons.​ Our stakeholders The Office's stakeholders include regulatees—the individuals subject to the conflict of interest regimes it administers—as well as Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report touches on all stakeholder groups, but its focus is on the public office holders who are subject to the Conflict of Interest Act. They are key stakeholders of the Office. In support of stakeholder communications and engagement, a key focus area of the Office's 2021-2024 strategic plan, the Office updated its list of stakeholders to allow for timely, proactive and fine-tuned messaging. As part of this project, it identified a new category of stakeholders dubbed “accelerators." These are entities or groups that are not subject to the Conflict of Interest Act or the Conflict of Interest Code for Members of the House of Commons but play a role in educational activities for regulatees. Examples are secretariats for administrative tribunal boards and organizers of events linked to Governor-in-Council appointees. By engaging more actively with accelerators, the Office can better adapt its outreach and education activities to the needs of regulatees. One of the Office's strategic objectives is to increase trust in and credibility of the Office with key stakeholders so they become stronger allies in the delivery of its mandate and can effectively manage conflict of interest issues. An important purpose of the stakeholders list project was to assess regulatees' individual needs to help improve education, outreach and service delivery. The Office also surveyed public office holders in January 2022 and will use the results to help optimize service delivery. Public office holders Public office holders(2,557)Reporting public office holders(1,106)Public office holders without reporting obligations(1,451) Individuals subject to the Act are collectively known as public office holders. They are all subject to its recusal requirement and core set of conflict of interest rules, as well as post-employment rules that apply indefinitely. Just over half of these individuals (56%) are subject only to those general rules which prevent them from furthering private interests when they are exercising official powers, duties or functions. They are referred to as “public office holders without reporting obligations." They include part-time members of federal boards, commissions and tribunals appointed by the Governor in Council and ministerial staff who work on average less than 15 hours a week. The rest (44%) are also subject to additional rules set out in the Act. They must confidentially disclose certain information to the Office and publicly declare some information. They are not allowed to have a second job or to hold controlled assets—assets whose value could be directly or indirectly affected by government decisions or policy, such as publicly traded securities. They are also subject to a post-employment cooling-off period. These public office holders are referred to as “reporting public office holders" and include ministers and parliamentary secretaries, ministerial staff who work on average 15 hours or more a week and full-time Governor-in-Council appointees. Snapshot of public office holders on March 31, 2022 Public office holders without reporting obligations 56% Reporting public office holders 44% Governor-in-Council appointees 20% Ministers* 2% Parliamentary secretaries 2% Ministerial staff 20% *Also subject to Conflict of Interest Code for Members of the House of Commons ​Turnover in 2021-202​2​​​​Appointed or reappointed​​Left officeReporting public office holders465449Public office holders without reporting obligations310223 Compared to the previous fiscal year, 11% fewer individuals were subject to the Act at the end of 2021-2022. This is likely due to turnover within ministerial offices resulting from the September 2021 election. The Office's quarterly statistical reports provide an accurate reflection of the fluctuations that occurred throughout the year. Turnover among public office holders doubled compared to the year before the COVID-19 pandemic began. It had stabilized during the pandemic, until the September 2021 election, which prompted a lot of movement among ministerial staff. Turnover is a workload indicator for the Office, which supports public office holders in achieving and maintaining compliance with the Act both during and after their term of office. When a reporting public office holder is appointed or reappointed, the Office must guide them through the initial compliance process and advise them on meeting ongoing reporting requirements; when they leave office, it must help them understand their post-employment obligations. The Office must also post information in the public registry and update its internal records. Our achievements Key Activities Reporting to Parliament​​Reporting to Parliament and testifying before its committees​​Compliance​Helping regulatees achieve and maintain compliance with the conflict of interest regimes​Direction and adviceGiving regulatees confidential guidance tailored to their individual situations​​​Education and outreach​Helping regulatees understand their obligations under the regimesEnforcement​Applying investigation and other enforcement provisions of the regimes as appropriate​​Public communications​​Educating and informing regulatees, the media and the general public​Collaboration and best practicesExchanging information with domestic and international counterparts Reporting to Parliament As an Officer of the House of Commons, the Conflict of Interest and Ethics Commissioner has a duty to report to Parliament, testify before parliamentary committees and respond to requests from Parliament. The Commissioner takes this duty very seriously and makes fulfilling it a top priority. Reflecting the Commissioner's independence, he reports on behalf of Canadians to Parliament directly, not through a minister. By June 30 each year, he submits an annual report on the administration of the Conflict of Interest Act to the Speakers of the House of Commons and Senate, who table it in their respective Chamber​. The Commissioner reports on examinations under the Act to the Prime Minister. The Office sends communiqués to parliamentarians when reports are tabled or released. Seven communiqués were sent in 2021-2022. The Commissioner also testifies before parliamentary committees about the Office and its work when invited to do so​. On May 28, 2021, the Commissioner appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics to discuss the Office's submission for the 2021-2022 Main Estimates. The Committee has oversight responsibility for the Office and reviews its annual spending estimates, as well as matters related to the Commissioner's reports under the Act. When parliamentary committees were reconstituted in the 44th Parliament, the Commissioner reached out to the Committee's new Chair to welcome him to the position and to offer to meet with him to share information about the Office and its work. In March 2022, the Committee passed a motion to re-table in the House the June 2021 report on its study of Questions of Conflict of Interest and Lobbying in Relation to Pandemic Spending. The Commissioner had testified before the Committee in November 2020 in relation to the study. He has reviewed the report, which features a number of recommendations related to the Conflict of Interest Act, and is prepared to discuss them with the Committee should he be called upon to do so. Compliance In support of its mission to ensure full compliance with the conflict of interest regimes it administers, the Office devotes most of its resources to helping regulatees achieve and maintain compliance with them. The Office identified a preventative approach to compliance assurance as a key area of focus in its 2021-2024 strategic plan. It involves providing regulatees with proactive guidance, including direction on issues involving real or potential conflicts of interest. It includes offering annual training for ministers, parliamentary secretaries and public office holders in select high-risk positions to strengthen their ability to identify potential conflicts of interest. As part of this approach, the Office will also identify new tools to help detect potential compliance issues, at-risk activities and areas that could raise concerns. Employees in the Advisory and Compliance division guide public office holders through the compliance processes under the Conflict of Interest Act. They give them confidential direction and advice, supported when necessary by legal opinions on individual files prepared by the Investigations and Legal Services division. To meet the Act's requirements in the area of transparency, they​ post public office holders' publicly declarable information in the public registry. The September 2021 election significantly affected the number of compliance processes the Office conducted in 2021-2022 to help reporting public office holders achieve and maintain compliance with the Act, as it led to a doubling of turnover among ministerial staff and Governor-in-Council appointees. To manage the additional workload and help reporting public office holders complete their initial compliance process within the 120-day deadline set out in the Act, the Office ensured staffing of critical advisory positions and streamlined some of its administrative procedures. It also consistently maintained the public registry in a timely manner in support of transparency and accountability. How does the Office help public office holders comply with the Act? By giving them advice when needed3,349 instancesBy posting their public information in the public registry804 postingsBy guiding them through their initial compliance process352 processes The Office communicates frequently with reporting public office holders throughout their term of office and less often with those without reporting obligations. It aims to contact all public office holders within three days of being notified of their appointment or reappointment. In 2021-2022, this service standard was met in 95% of cases, surpassing the target of 80%. Over the last three years, the service standard was met, on average, at a rate of 89%. When are public office holders contacted by the Office? Once a year1,130 reminders / reviewsWhen they are first appointed or reappointed​775 communicationsWhen they leave office672 communications Initial compliance process The initial compliance process is a critical step that all reporting public office holders must complete to achieve compliance with the Conflict of Interest Act. It is an opportunity for them to learn the rules, reflect on areas where they might potentially find themselves in a conflict of interest and address potential issues. Once they have completed this process, they are well positioned to maintain their compliance with the Act throughout their term of office and thus avoid any conflict of interest. Public office holders are welcome to contact the Office for one-on-one personal advice about their situation at any time. Initial compliance is a two-stage process that must be completed within 120 days after a reporting public office holder's appointment or reappointment (when there is an interruption between the appointment and reappointment). In the first stage, they must submit to the Commissioner, within 60 days of their appointment, a Confidential Report outlining their assets, liabilities, income, current and past activities and any other information the Commissioner considers necessary, such as the names of relatives or friends that have dealings with the federal government. In the second stage, advisors in the Office review the Confidential Report and discuss with the reporting public office holder any measures that may be needed to comply with the Act. Compliance measures include the divestment of controlled assets, which they are not allowed to hold or acquire during their term of office, and withdrawal from outside activities. Additional appropriate measures under section 29 of the Act could also be determined and would include the establishment of conflict of interest screens. The Commissioner has delegated to the Director of Advisory and Compliance the authority to grant reporting public office holders an exception, under subsection 15(3) of the Act, to its prohibition on outside activities, for involvement in organizations of a philanthropic, charitable or non-commercial character if it is not incompatible with their public duties. Reporting public office holders must divest any controlled assets by selling them to a third party in an arm's-length transaction or by placing them in a blind trust. The Commissioner has delegated to the Director of Advisory and Compliance the authority provided under subsection 27(10) of the Act to exempt certain controlled assets from divestment if they are of such minimal value that they do not constitute any risk of conflict of interest in relation to a reporting public office holder's official duties and functions. In 2021-2022, there were 53 divestments of controlled assets, including 29 by sale and 24 by blind trust. The Office issues reimbursement orders to reporting public officer holders' organizations for reasonable costs for establishing, maintaining and dismantling blind trusts. The Corporate Management division reviews and analyzes those costs, as well as the costs for withdrawal of business and commission fees. It helps the Commissioner determine the reasonableness of the fees so reimbursement orders may be issued. In 2021-2022, the Commissioner issued 165 orders for reimbursement totalling just over $1 million, up 20% from the previous year. Factors contributing to this increase may be reflective of a high percentage of blind trusts established, the increased costs for establishing blind trusts, and the May 2021 update of an information notice on the reimbursement of these costs. The initial compliance process is completed after the Office prepares a Summary Statement of the Confidential Report, as well as any applicable public declarations, and the reporting public office holder signs them. They must do so within 120 days of their appointment. The purpose of the 60-day and 120-day deadlines is to ensure reporting public office holders arrange their affairs promptly to prevent conflicts of interest. The Commissioner has discretion when imposing a penalty for failure to meet these deadlines. Delays in the Office being notified of or learning about new appointments mean it sometimes cannot immediately reach out to reporting public office holders to inform them of their obligations under the Act, potentially resulting in missed deadlines. In 2021-2022, 76% of reporting public office holders submitted the information required for the initial compliance process on time. Initial Compliance Process for Members of the House of Commons First letter sent by office (with copy of Act and summary of applicable rules) 465 first letters sentReporting public office holders files Confidential Report within 60 days after their appointment or reappointment Office reviews Confidential Report​​Reporting public office holder participates in initial compliance call with advisor from Office​282 initial compliance calls made​Office sends intermediate letter with Summary Statement and other public declarations​​​307 inte​rmediate letters sentReporting public office holder signs and returns Summary Statement and other public declarations within 120 days after their appointment or reappointment 303 final letters sentCommissioner sends final letter, signalling completion of initial compliance process Office updates public registry 322 summary statements posted Once the initial compliance process has been completed, the Summary Statement and any required declarations are posted in the public registry. In 2021-2022, 352 initial compliance processes were completed and 322 summary statements were posted in the public registry. The Office concentrated its efforts on completing these processes as quickly as possible to ensure that reporting public office holders achieved compliance with the Act. This is in line with the number of compliance processes completed in the previous year. Discrepancies between initial compliance processes completed and summary statements posted are attributable to some processes having been completed in one fiscal year and the statements posted in another. The Office began developing a new system which in fiscal year 2022-2023 will replace the declaration portal that regulatees currently use to submit their public declarations. It will give reporting public office holders a fully secure, fast and easy way to submit information required under the Act, communicate with their advisors, keep track of their compliance requirements and request reimbursement of blind trust fees. (Please see “Our Infrastructure" section.) Process for public office holders without reporting obligations First letter (sent with copy of Act and summary of applicable rules) 310 first letters sentPost-employment letter 223 post-employment letters sent The Office communicated with public office holders without reporting obligations on several occasions throughout the year. For example, it sent them links to the Commissioner's 2020-2021 Annual Report under the Act, invited them to educational sessions, included them in the January 2022 survey of public office holders, and offered tailored presentations to organizations with public office holders without reporting obligations. Ongoing reporting requirements After completing the initial compliance process soon after their appointment or reappointment, reporting public office holders must meet various reporting requirements throughout their terms of office to comply with the Conflict of Interest Act. This is very important because changes to their personal situations over time, as well as other developments, may modify their current compliance arrangements, creating the potential for conflicts of interest to arise. Material changes could include buying or selling a house or a car, incurring or paying off a loan over $10,000, or any new ties between relatives or friends and government entities. When reporting public office holders disclose such information to the Office, advisors can help them prevent and avoid conflicts of interest. In March 2022, the Office organized an educational session for ministerial staff. Its focus was material change because a number of ministers' offices had requested more clarity on when their staff are required to declare changes to the Office. Material change was also one of the top-ranked topics in the January 2022 survey of public office holders. Ongoing reporting requirements Annual review​​1,130 annual reviews initiated and 1,127 receivedMaterial changes Gifts or other advantages Private flights accepted by ministers and parliamentary secretaries for themselves, their families or ministerial staff Recusals Firm offers of outside employment and their acceptance 250 firm offers and acceptances disclosed Survey of public office holders To improve service delivery and better understand the needs of public office holders in helping them meet their obligations under the Act, in January 2022 the Office conducted a survey of public office holders for the first time since the Act took effect. It was primarily about subject areas of interest to regulatees, their overall opinion of their interactions with the Office, and communication tools. The survey focused on the Act, so it was sent to individuals who are subject only to the Act. It was not sent to ministers and parliamentary secretaries, because they are also subject to the Conflict of Interest Code for Members of the House of Commons. The survey generated a response rate of slightly over 30%, producing valuable feedback. The survey indicated that over 61% of the respondents had been public office holders for a period of 1 to 5 years; 82% opted for taking the survey in English and 18% in French; and Governor-in-Council appointees made up nearly 80% of respondents, with ministerial staff making up 20% of the respondents. The following observations are based on an analysis of the results: 77% of respondents felt positively about the Office;84% of respondents were satisfied with their most recent one-on-one interaction with the Office;a number of respondents commented on the value of plain language in Office communications. It can be stated that the survey responses represent the views of all public office holders within ±3.8 percentage points 9.5 times out of 10. The Office will use the results to improve its communications products and service delivery. In the interests of transparency, it will make them public in a detailed report in 2022-2023. Post-employment Post-employment rules are important in ensuring that former public office holders do not take advantage of their previous office, colleagues or contacts in entities with which they had direct, significant and official dealings. The Conflict of Interest Act contains post-employment provisions that apply to public office holders after they leave public office. Some apply to all former public office holders for life. Additional rules apply to former reporting public office holders during a one- or two-year cooling-off period. While in office, public office holders must also not let themselves be influenced by plans for, or offers of, outside employment. Reporting public office holders must disclose all firm offers of outside employment to the Office within seven calendar days after receiving them. If a reporting public office holder is considering accepting an offer, their advisor will provide advice on the permissibility of accepting it in light of their current or post-employment obligations. If they subsequently accept an offer of outside employment, they must also disclose the acceptance in writing to the Office, as well as to other authorities specified in the Act, within seven calendar days. Their advisor will then give them additional guidance on their current and post-employment obligations. Once they are in post-employment, former reporting public office holders are no longer required to report acceptance of employment. The Office monitors sources of public information regarding their employment activities after leaving public office to ensure they comply with the Act's post-employment provisions and to check that those activities match the information they provided to the Office when entering post-employment. In June 2021, the Office hosted two teleconferences (one each in English and in French) on offers of outside employment and recusals. In December 2021, the Office hosted an educational session on post-employment and offers of outside employment for ministerial staff, who are reporting public office holders under the Act. In 2021-2022, the population of former reporting public office holders increased by 18% and the number of former public office holders without reporting obligations rose by 5%. The Office sent twice as many post-employment letters as it did the year before. This may be attributable in part to turnover resulting from the September 2021 election. Moreover, the number of firm offers of outside employment and acceptances disclosed to the Office tripled compared to the previous year. The Office's proactive educational activities about these requirements of the Act may have contributed to the increase in such disclosures. ​ Public registry Making up-to-date compliance information accessible to the public contributes to transparency and enables public scrutiny; powerful tools that are key to the effectiveness of conflict of interest regimes. The Office maintains a public registry of all of the information about individual public office holders and Members of the House of Commons that the Commissioner is authorized to make public. A searchable database, it is frequently accessed by regulatees, the media, members of the public, governments around the world and international ethics practitioners. Improvements to the registry are coming in fiscal year 2022-2023. It will become part of an integrated system that will include a new declaration portal and a new internal case management system, ensuring postings are timely and accurate and enhancing the user experience. However, there will be no changes to the types of information it contains since it is reflective of the requirements of the Act. (Please see “Our Infrastructure" section.) In 2021-2022, the Office posted a total of 1 250 items in the public registry, down 10% from the previous year. Contributing to this decrease is the high turnover among regulatees. This is typical of the period before and during an election call. There were over 65,000 public registry page views in 2021-2022, which is in line with the previous year. During the September 2021 election, there was a slight dip in public registry page views and activity, followed by an increase in page views and postings. The registry contains a dedicated page for each regulatee and, depending on current events, some pages are consulted more often than others. Over the past few years, there has been an overall increase in the number of public registry visits, with a significant spike in the last quarter of 2021-2022. This may reflect a higher level of interest in the Office's mandate, a better understanding of the rules that apply to regulatees and greater awareness of the registry following the election.​ What did public office holders declare in 2021-2022? Summary statements322​Assets​139​​Outside activities​120​Liabilities*​​82​Gifts or other advantages​41​Agreed compliance measures​​25​Recusals​21​Post-employment waivers or exemptions​​13​Other​5​Travel*​3 *ministers and parliamentary secretaries only Direction and advice Prevention—that is, recognizing and taking measures to avoid conflict of interest situations—is a major focus of the regimes administered by the Office. Public office holders must familiarize themselves with the rules and take appropriate measures to prevent conflicts of interest. As part of its preventative approach to compliance assurance, the Office provides public office holders with proactive guidance, including direction on issues involving real or potential conflicts of interest. The Commissioner also encourages public office holders to seek direction and advice from the Office when they come across situations that may be difficult for them to navigate. Advice is provided by advisors based on the facts before them and in accordance with pre-established precedents confirmed by the Commissioner or following consultation with the Commissioner. This requires prior review by the Commissioner for certain reporting public office holders such as ministers, parliamentary secretaries, heads of agencies, deputy ministers and chiefs of staff. The Office also offers pre-employment advice to candidates for positions as public office holders, when requested. To ensure it meets regulatees' needs in a timely manner, the Office has put in place a service standard of three business days for responding to requests for advice. This standard was met in over 90% of cases in 2021-2022, surpassing the 80% target. The Office responded to 3,349 requests for advice from public office holders, up 50% from the year before. In the January 2022 public office holders survey, one of the greatest value-adds highlighted by respondents was one-on-one access to an advisor. The Commissioner recognizes the importance of ensuring the confidential advice it provides to public office holders is clear and consistent and has made this a priority for the Office since his appointment. Consistency of advice was also identified as an important element in the January 2022 public office holder survey. There is no one-size-fits-all approach that can apply to every situation, as confidential advice is tailored to the circumstances of each individual case, since there may be factors that can change the outcome of a decision in cases that are similar. The Office continues to take measures to ensure consistency. It records the Commissioner's interpretations of the Act in an internal practice manual that advisors can consult. Whenever a public office holder consults the Office, the consultation is added to their file for future reference. This process helps advisors better understand the realities faced by public office holders and continue to adapt advice and messaging to help them prevent conflicts of interest. The Commissioner also maintains an ongoing dialogue with advisors. The Office tracks the types of advice requested so it can identify trends that may impact its workload and identify training needs. For example, there was a 50% increase in requests for advice relating to post-employment in the two quarters following its June 2021 educational session on post-employment and offers of employment. What did Public Office Holders ask about? ​Material changes34%General obligations24%​​Outside activities​22%​Post-employment obligations​​17%​Gifts or other advantages​4% Education and outreach The Commissioner discussed the importance of education in a January 2022 op-ed published in The Hill Times. He noted that complying with the Conflict of Interest Act is not about avoiding penalties but about doing the right thing and encouraged public office holders to educate themselves about the Act's rules. In May 2021, the Office issued an updated information notice on reimbursement of costs associated with divestment of assets and withdrawal from activities. In October 2021, it issued an information notice on the meaning of “friendship" for the purposes of the Act. While noting that the Commissioner determines the existence of a friendship on a case-by-case basis, it sets out several indicators that may help determine whether an individual is a friend within the meaning of the Act. It also discusses public office holders' obligations under the Act when it comes to friendships. The Office gave 19 presentations to offices and organizations with regulatees subject to the Act in 2021-2022, almost double the number of presentations compared to the previous year, reaching almost 600 regulatees​. Regulatees can request presentations for their organizations by contacting the Office, and advisors may offer presentations when speaking to regulatees. The Office has found that online educational sessions offer a convenient and flexible way to deliver training. They enable it to reach more regulatees whose busy schedules might not permit them to attend in-person sessions. And they make it possible for participants to pose questions anonymously. Providing online training is also feasible within the Office's current resourcing levels, as the technology is provided by the House of Commons IT team. In June 2021, the Office hosted two teleconferences (one each in English and in French) on offers of outside employment and recusals. In December 2021, the Commissioner hosted a teleconference on post-employment rules and offers of outside employment for ministerial staff. In early January 2022, several ministerial offices asked for a presentation for their ministerial staff. Given the number of requests and the number of new ministerial staff who were being onboarded, the Office set up one educational session in each official language to handle the numerous requests and consulted with the ministerial offices on the most appropriate timing and topic. Therefore, in March 2022, prompted by a high volume of information requests from ministers’ offices, another educational session was offered to ministerial staff, providing an overview of their obligations with a focus on the items that should be kept top of mind. There were 170 participants in this session. A doubling of the number of firm offers and acceptances of outside employment disclosed to the Office in 2021-2022 compared to the previous year indicates that better awareness of the rules results in improved compliance.​ The Office reached out to public office holders on Twitter (@EthicsCanada) as an additional means of helping them understand their obligations under the Act and how to comply with it. Its social media posts are not meant to replace other communications but serves to supplement current education practices such as personalized emails from advisors, general emails from the Commissioner and information notice​​s on the website. Indeed, the January 2022 survey of public office holders revealed that only 30% of regulatees rely on Twitter as a source of information about the conflict of interest regimes administered by the Office. This is in line with statistics on Canadians' reliance on Twitter as a news source. Enforcement While the Office seeks to ensure full compliance with the Conflict of Interest Act, there are several enforcement mechanisms available to address non-compliance and the Commissioner does not hesitate to apply them as necessary. Their application serves to encourage compliance rather than to punish. The January 2022 survey of public office holders revealed that some do not view the Act's rules as flexible and that they do not reflect their positions since the same rules apply to all reporting office holders— from interns in a minister's office to ministers themselves. There is an opportunity for the Office to better explain the reasoning behind these rules to foster more understanding. Administrative monetary penalties The Commissioner can impose administrative monetary penalties of up to $500 for failures to meet certain reporting requirements of the Act within established deadlines. In 2021-2022, the Office issued 18 administrative monetary penalties, seven more than in the previous year. It also updated its procedures to give public office holders the option of paying penalties by credit card. When an administrative monetary penalty is issued, the Act requires the Commissioner to make public the nature of the violation, the name of the public office holder and the amount of the penalty. The Office posts penalties in the public registry and publishes them on social media. Tweeting administrative monetary penalties supports the Commissioner's commitment to openness and transparency and can also have a deterrent effect. The Office's tweets relating to penalties tend to generate higher engagement rates on average than its general informational tweets but are seen by fewer Twitter users. Compliance o​rders Under section 30 of the Act, the Commissioner may order a public office holder to take any compliance measure to comply with the Act, such as submitting documents for their annual review, divesting controlled assets or ceasing prohibited activities. The Commissioner issued 15 compliance orders in 2021-2022, five more than in the previous year. Like administrative monetary penalties, compliance orders are posted in the public registry and may be shared on social media. Examinatio​ns Under sect​io​n 44 of the Act, the Commissioner can launch an examination of a possible contravention of the Act at the request of a Senator or Member of the House of Commons who provides reasonable grounds to believe the Act has been contravened. The Office received nine requests for investigations under the Act from Members in 2021-2022. Under s​ection 45, the Commissioner may conduct an examination on his own initiative if he has reason to believe that a current or former public office holder has contravened the Act. The Commissioner may decide to do so based on information from various sources, including media reports and complaints from members of the public. The Commissioner also has the discretion to conduct an inquiry on his own initiative. The Office received 15 requests for examinations under the Act from members of the public in 2021-2022. The Commissioner issues a public report when an examination is completed. When the Commissioner decides to discontinue an examination launched under section 44 of the Act, a discontinuance report is issued. However, when the Commissioner discontinues an examination launched under section 45, he is not required to issue a report. In 2021-2022, the Office issued two examination reports under the Act. One focused on the conduct of the Right Honourable Justin Trudeau, Prime Minister of Canada. The other focused on the conduct of the Honourable Bill Morneau while he was Minister of Finance. Both reports, which were issued on May 13, 2021, related to two matters involving the private interests of WE, an international development charity and youth empowerment movement founded by Messrs. Marc and Craig Kielburger. It had been alleged that Mr. Trudeau and his relatives were involved with WE and that the Morneau family had close ties with WE. One of the matters was a decision to award WE the administration of the Canada Student Service Grant (CSSG), a proposed government student relief initiative to encourage youth to participate in national service in the context of the COVID-19 pandemic. The other was a decision to fund WE's proposed Social Entrepreneurship program, a digital program providing entrepreneurship expertise and mentorship opportunities. Both reports also focused on the same provisions of the Act: subsection 6(1), section 7 and section 21. Subsection 6(1) prohibits public office holders from making or participating in the making of a decision that would place them in a conflict of interest. Section 4 states that a public office holder is in a conflict of interest when they exercise an official power, duty or function that provides an opportunity to further their private interests or those of their relatives or friends or to improperly further another person's private interests. Section 7 prohibits public office holders from giving preferential treatment to a person or organization based on the identity of a representative of the person or organization. Section 21 requires public office holders to recuse themselves from any discussion, decision, debate or vote on any matter in respect of which they would be in a conflict of interest. In the Trudeau III Report, the Commissioner found that Mr. Trudeau did not contravene subsection 6(1), section 7 or section 21 of the Act. For a contravention of section 7 to occur, the treatment a public office holder gives to a person or organization must be more favourable than the treatment they might give to a similarly situated person or organization, and there must be a prior relationship between the public office holder and the representative. Mr. Trudeau's decision to approve the CSSG proposal with WE as the administrator of the program was not, in the Commissioner's view, motivated by the identity of any third-party representative, given the absence of a personal relationship between Mr. Trudeau and Messrs. Marc and Craig Kielburger. The Commissioner was satisfied that Mr. Trudeau did not give preferential treatment to WE and therefore did not contravene section 7 of the Act. The Commissioner was satisfied that there was no opportunity to further Mr. Trudeau's own interests or those of his relatives from WE's role as administrator of the CSSG or from its Social Entrepreneurship proposal. He determined that Mr. Trudeau had the opportunity to further WE's private interests regarding its Social Entrepreneurship proposal and its selection as the administrator of the CSSG. However, for there to be a contravention of subsection 6(1), WE's private interests would have to have been furthered improperly. In the Commissioner's view, there was no evidence of impropriety in relation to Mr. Trudeau's decision making in relation to either matter. The Commissioner therefore found that Mr. Trudeau did not contravene subsection 6(1) of the Act. The Commissioner considered whether Mr. Trudeau's relatives' relationship with WE, which created an appearance of a conflict of interest, was captured by the definition of conflict of interest under section 4 of the Act. He determined that without an actual conflict of interest or a clear legislative prohibition against apparent conflicts of interest, he could not conclude that a contravention occurred. Although Mr. Trudeau has acknowledged publicly that he should have recused himself because of the appearance of a conflict of interest, there is no requirement to do so under the Act in such circumstances. Section 21 provides that recusal is required only in instances where the public office holder would be in a potential conflict of interest. The Commissioner therefore determined that Mr. Trudeau did not contravene section 21 of the Act. In the Morneau II Report, the Commissioner found that Mr. Morneau contravened subsection 6(1), section 7 and section 21 of the Act. The Commissioner was satisfied there was no opportunity to further Mr. Morneau's own interests or those of his relatives in the matters under examination. Having examined the nature of his relationship with Mr. Craig Kielburger and the personal and professional interactions between them, he determined they were friends within the meaning of the Act. Consequently, he found that Mr. Morneau had the opportunity to improperly further WE's private interests. The Office has traditionally favoured a narrow interpretation of “friend" to include only the public office holder's closest personal friends. The Commissioner believes it is necessary to broaden the scope of the term to capture relationships where personal and professional interactions become intertwined to such an extent that it becomes difficult to draw the line between the two. In such cases, the public office holder's judgment in the exercise of their official powers and duties can reasonably be impaired. The friendship between Mr. Morneau and Mr. Craig Kielburger created a potential conflict for Mr. Morneau when called upon to make a decision that would further WE's private interests. Thus, any decision made by Mr. Morneau that provided an opportunity to further WE's private interests was made improperly. The Commissioner therefore found that Mr. Morneau contravened subsection 6(1) of the Act. For a contravention of section 7 to occur, the treatment a public office holder gives to a person or organization must be more favourable than the treatment they might give to a similarly situated person or organization, and there must be a prior relationship between the public office holder and the representative. The Commissioner found no evidence that Mr. Morneau was directly involved in a departmental decision to propose WE as the administrator of the CSSG. Nor did he appear to have provided instruction or direction to anyone associated with WE's Social Entrepreneurship proposal. However, his ministerial office had an unusually high degree of involvement in past files relating to WE that was also apparent in the matters under examination. The Commissioner was of the view that Mr. Morneau gave WE preferential treatment by permitting his ministerial staff to disproportionately assist it when it sought federal funding. He was of the view that this unfettered access to the Office of the Minister of Finance was based on the identity of WE's representative, Mr. Craig Kielburger. The Commissioner therefore found that Mr. Morneau contravened section 7 of the Act. Mr. Morneau should have reasonably known that he was in a potential conflict of interest because of his relationship with Mr. Craig Kielburger when he received WE's Social Entrepreneurship proposal and when he was later advised that WE would likely play an important role in the student relief initiative. The Commissioner found that by having failed to recuse himself from participating in related briefings, discussions and votes, Mr. Morneau contravened section 21 of the Act, as his participation provided an opportunity to improperly further WE's private interests because of his friendship with Mr. Craig Kielburger. Barring exceptional circumstances, the Office's target is to conduct examinations within a 12‑month timeframe. Since the Commissioner took office in 2018, 14 reports have been published under the Act. The average time to complete an examination, including examinations prompted by referrals from the Public Sector Integrity Commissioner​, is just over eight months. This average also includes reports on Public Sector Integrity Commissioner referrals where an examination is not warranted. ​​The Office makes it a priority to produce examination reports with due dispatch to ensure that Canadians are well informed in a timely manner of any contravention of the Act, especially when the matter under examination has been made public. To complete investigations within a reasonable timeframe, the Office relies on the cooperation of the subjects of the examinations and other witnesses. As of March 31, 2022, the Office was not working on any examinations under the Act. Examination case files When the Office receives information about a possible contravention of the Act, whether from a Senator or Member of the House of Commons, media reports or complaints from members of the public, it may open a case file. When a case file is opened, the Office conducts an initial review of the matter. Some of these reviews may lead to examinations, which, barring exceptional circumstances, the Office aims to complete within 12 months. When an examination is not found to be warranted, the case file is closed. Overall, there was a 28% decrease in the number of case files in 2021-2022. While there was an increase in case files during the second quarter of the fiscal year, which coincided with the electoral period, there was a sharp drop in the number of case files opened during the last two quarters. However, in February and March 2022, the Office received over 1,000 requests from members of the public asking the Commissioner to investigate the participation of Members and ministers in the World Economic Forum. Since the requests did not provide sufficient information to warrant an investigation and they were all related to the same topic, they were counted as a single case file by the Investigations and Legal Services division. ​ Examination case files in 2021-2022 How many case files were opened and closed?​​Total case files (a case file is a concern that is reviewed by the Office)​​33​Ongoing​​3​Closed without an examination28​Closed with publication of report2Who was the subject of each case file?*​Current or former minister and parliamentary secretary23​Current or former public office holder17​​​Person not subject to the Act​0​​What was the source of these case files?​​Member of the general public**15​ ​Within the Office5​Member of the House of Commons9​​Media4​​​Office of the Public Sector Integrity Commissioner0​​​​What was the nature of the concern?*​Furthering a private interest19Duty to recuse15​Post-employment rules​5Influence6​Preferential treatment​10​​Private air travel​1​Prohibited activities​2Public declaration​5​Insider information​0​Gifts and other advantages​1​Material changes2​ *some case files have more than one subject or concern​ **Members of the House of Commons are no longer subject to the Code when an election is called so their requests for investigations were counted as requests from members of the public. Referrals from the Public Sector Integrity Commissioner Matters may be referred to the Commissioner by the Public Sector Integrity Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act. It provides another mechanism for Canadians to request investigations and for the Commissioner to be made aware of possible issues. When such a referral is received, the Commissioner is required, under section 68 of the Conflict of Interest Act, to issue a public report whether or not an examination is launched. No such referrals were received or reported on in 2021-2022. Oversight Information about potential non-compliance can serve as a basis for the Office to reach out to regulatees with advice or direction, or to apply the regimes' enforcement provisions as appropriate. To strengthen its oversight of potential non-compliance with the conflict of interest regimes it administers, in May 2022 the Office staffed a new data analyst position in the Communications, Outreach and Planning division. Sources of public information are monitored, particularly in relation to positions that have been evaluated as potentially having a higher risk of conflict of interest. Special attention is paid to outside activities in which reporting public office holders may be engaged and former public office holders' employment after leaving public office.​ Public communications​ In support of public education about the regimes that it administers, the Office makes a range of information available on its website, is active on social media, responds to inquiries from the media and members of the public, and delivers presentations to the interested public. Below is a summary of its activities in these areas for 2021-2022. The Office monitors the volume of relevant Twitter mentions, news mentions, website activity and mentions during Question Period. In general, high mentions lead to workload increases for the Office. Tracking these trends can help the Office prepare for an influx of public and media inquiries, for example, or become aware of issues that might relate to its work. The Office publishes this data in its quarterly statistical reports. We​bsite The Office continued to maintain its website as an important source of information to help educate and inform regulatees, the media and the public. The number of website visitors increased by 19%, for a total of 52,765 visitors. In July 2021, it added to the website a detailed chronology that highlights milestones—dating back almost to Confederation—in the development of Canada's federal conflict of interest regimes and their administration. The chronology is a useful research tool that brings together information from a range of sources and details how the culture of ethics and integrity has been shaped in Canada. Soc​​ial media The Office's social media presence allows it to be aware of and participate in relevant discussions and provides an additional source of information about the Office and the public registry. The Office continued to be active on social media. The total number of followers for @EthicsCanada and @EthiqueCanada grew by 16% (3,596 followers), further increasing the Office's social media reach. It tweeted 159% more times than in the previous year, sending one to two tweets per day. More than 6% of visits to the Office's website were from links on Twitter and the Office's own tweets drove 2% of the traffic. Over half of the Office website's traffic resulted from an Internet search. Although difficult to pinpoint, social media conversations relating to ethics can lead to independent searches of the Office website to verify facts or find more information. While the January 2022 survey of public office holders revealed that Twitter is not used as an information source by most public office holders, it is a preferred tool used by the media, who have been identified as key stakeholders of the Office. The Office's tweets can help them report accurately on the Office and its work. When the Office releases a report, its associated tweets often attract attention that may lead to additional inquiries from the public and the media. Media and public in​quiries The Office fielded nearly 3,500 information requests received from the media and members of the public by phone, email, post and fax, as well as through direct messages on Twitter. The Communications, Outreach and Planning division has developed procedures and processes to ensure that it provides accurate, timely and useful information to the individuals and groups seeking information. Although the conflict of interest regimes' strict confidentiality provisions mean no information can be provided about individual cases, the Office strives to provide as much information as possible about the rules and their general application. The Office was also copied on a number of emails that were not relevant to its mandate. Its practice is to respond only to those that are directly addressed to the Office. Such emails represented 60% of total correspondence received in 2021-2022. The media can help the Office provide accurate information to the public about the conflict of interest regimes that it administers. In 2021-2022, it received 47% fewer requests from the media compared to the previous year. Many of those requests sought information about the Trudeau III and Morneau II reports and were received in the months preceding their May 2021 release. Direct inquiries about the status of a current case file or public office holder constituted 80% of media requests. Only 20% related to general inquiries about the role and mandate of the Office. Journalists have demonstrated an increased understanding of the regimes, which may have resulted in fewer requests for information about general topics. The Office met its four-hour service standard for responding to media inquiries in 100% of cases. The Office also took a proactive approach in a particular case. It had received several media inquiries about the compliance of former public office holder Dominic Barton with the Act's post-employment rules, but because of confidentiality requirements, it could not provide any information. The Office later received consent from Mr. Barton to share information about the matter and reached out to the journalists who had requested information about it. This move contributed to transparency and helped provide Canadians with information that would allow them to be better informed. The Office started categorizing by subject the information requests it receives, to see if any trends can be observed. For instance, does an increase in media inquiries about a particular topic prompt more requests about it from members of the public and from public office holders seeking advice? This kind of information helps the Office adapt its education and outreach activities as appropriate. For example, there were several inquiries about regulatees' general obligations, gifts, post-employment and outside activities, all of which align with the categories the Office tracks when it provides advice to regulatees. The Office consequently tweeted about these subjects to help educate the public. The data also revealed that 15% of media requests received in the past year related to ongoing public investigations while 65% were direct inquiries about a regulatee's compliance. Because of confidentiality restrictions, the Office cannot provide any information about individual regulatees other than what is already in the public registry. The Office provides additional context about the administration of the Act the Code when possible. Just over a third of public inquiries were complaints about various subjects. The Office generally cannot act on these complaints because they are either outside of its mandate or there are no reasonable grounds to believe that a contravention has occurred based upon the information received in the query. When relevant, complainants are asked to fill out an investigation request form. If they submit a completed form, the Office notifies them that their information will be reviewed. Over 1,000 of the public and media inquiries received by the Office during the year were from members of the public asking the Commissioner to investigate the involvement of Canadian parliamentarians in the World Economic Forum. These requests were received in February and March 2022. The Communications, Outreach and Planning division responded on behalf of the Office to each one by explaining the mandate and role of the Office and providing information about the investigation process. The responses were tracked in its public inquiry statistics. In the first quarter of the fiscal year, the Office achieved its service standard for responding to public inquiries within 10 days at 80%. Although this met the threshold set by the Office, an analysis of the response process revealed there were some efficiencies to be gained and it was changed slightly. The Office was subsequently able to achieve its service standard at higher rates, ending the year with an 89% achievement of its 10-day service standard. Collaboration and best practices Thanks in part to the technology that makes it possible to have productive and effective meetings virtually, the Office continued to maintain and strengthen connections with officials and organizations in Canada and other countries in 2021-2022. Domestic o​utreach The Commissioner participated in the annual meeting of the Canadian Conflict of Interest Network (CCOIN) in September 2021 and in its semi-annual meeting in March 2022. CCOIN is made up of federal, provincial and territorial conflict of interest commissioners. The Office coordinates information sharing within the network, gathering and disseminating information and materials acquired by or developed in various Canadian jurisdictions. Several Canadian universities asked the Office to provide an overview of the Commissioner's role and mandate to give students an opportunity to gain a firsthand understanding of Canada's federal conflict of interest regimes. The Commissioner delivered a presentation at Carleton University and another at York University alongside Information Commissioner Caroline Maynard. In July 2021, the Commissioner participated in Quebec Ethics Commissioner Ariane Mignolet's podcast with Senate Ethics Officer Pierre Legault. They discussed conflict of interest and ethics jurisdictions across Canada and the benefits of belonging to networks of ethics practitioners. In February 2022, the Office submitted com​ments on the draft update of the Lobbyists' Code of Conduct during a consultation process initiated by Commissioner of Lobbying Nancy Bélanger. Participating in this process aligned with the principles of the Memorandum of Understanding signed by the two commissioners in March 2018. The Commissioner met privately with other agents of Parliament to discuss common issues and concerns, and Office employees liaised with their counterparts in those agents' offices. International outr​each The Office always considers the value added to its mandate when it agrees to participate in international events. Sharing best practices, learning about the ways conflict of interest rules are applied and listening to the public discourse around ethics issues in other jurisdictions are part of ongoing developmental activities for members of the Office. As the field of public ethics continues to change and grow, keeping abreast of ongoing developments can help inform the Office's work. The Office remains an active member of the Réseau francophone d'éthique et de déontologie parlementaires (RFEDP) [link in French only] within the Organisation internationale de la Francophonie. The RFEDP fosters the sharing of best practices to enhance expertise and help the parliaments of Francophonie member countries adopt ethics principles and conflict of interest rules. In 2021-2022, the Office contributed to two RFEDP working groups focused on training and best practices. In November, the Commissioner and several other members of the Office participated in the RFEDP's two-day annual general meeting and the Director of Advisory and Compliance was nominated to its Bureau. The Office also continues to be an active member of the Council on Governmental Ethics Laws (COGEL), a U.S.-based international not-for-profit organization of government ethics practitioners in which other Canadian conflict of interest and integrity offices also participate. In December, the Commissioner and Office representatives attended COGEL's virtual annual conference. The Director of Communications, Outreach and Planning is a member of the program planning committee for COGEL's 2022 conference, an in-person event that will be held in Montreal in December. International outreach activities in 2021-2022 included participation by the Commissioner and other senior Office representatives in bilateral meetings with international counterparts to discuss Canada's ethics regimes and share best practices, and in other events. The Office also responded to several requests for information from or on behalf of international organizations. In September 2021, communications methods and tools were discussed with France's Haute Autorité pour la Transparence de la vie publique. In October, the Office met with the Public Sector Directorate of the Organisation for Economic Co-operation and Development (OECD) to answer its questions about best practices that could be implemented by the Office of the Commissioner for Standards in Public Life in Malta. In November, the Commissioner participated in a panel at the one-day conference on ethical standards in government organized by the United Kingdom's Institute of Government. The panel was entitled “What can the UK learn from how other governments uphold standards?" Commissioner Dion participated alongside the Director of Policy Transparency International UK and the Commissioner for Standards at the Northern Ireland Assembly. The invitation to this event resulted from the Commissioner's March 2021 appearance before the United Kingdom's independent Committee on Standards in Public Life to discuss how Canada's federal ethics regimes work. That same month, the Office sent comments on the Third Resolution for the 9th Session of the Conference of the States Parties to the United Nations Convention Against Corruption through Global Affairs Canada. The resolution, “Enhancing the use of beneficial ownership information to facilitate the identification, recovery and return of proceeds of crime," seeks to address asset recovery. In December, the Office was approached by the Treasury Board of Canada to provide input into the OECD's integrity indicators. Its input related to reporting requirements of appointed and elected public officials and general information about Canada's federal conflict of interest regimes. This project was part of the OECD Pub​lic Integrity Indicators Portal, which will compile data to provide an accurate picture of the state of public integrity among OECD countries. The Office will monitor the portal, which will provide access to comparative data for benchmarking purposes. In February 2022, it shared information about Canada's public integrity framework with representatives of Israel's Ministry of Justice. Finally, in March, Office representatives attended the OECD's Global Anti-Corruption and Integrity Forum. The theme was “Renew governance, business, finance, sustainability, development aid, taxation and more, with integrity." When approached, the Office is pleased to share best practices relating to the administration of the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. In March 2022, the Commissioner met with the Honourable Stéphane Dion, Ambassador to Germany and Special Envoy to the European Union, to discuss sharing best practices with the Office's counterparts in Armenia. Later that month, it was contacted by the Embassy of Mongolia and agreed to meet with its counterparts from Mongolia. Future meetings may take place during the next fiscal year. Our ​tools The Office's accomplishments result from the hard work, dedication and resilience of its employees in implementing the Commissioner's vision, with the support of a sound internal management framework. Our people To ensure the Office has the human resources it needs to fulfill its vision and achieve its mission, two staffing processes were completed or initiated in 2021-2022. The Office continued to operate primarily in a telework environment. It developed a new telework policy that will take effect in the new fiscal year. Under it, the Office will adopt a hybrid model where employees may choose, in consultation with their director, to work from home some or all of the time, while continuing to ensure the Office delivers on its mandate. The flexibility this approach gives employees can help them achieve a better work-life balance and reduce stress, thereby helping the Office retain and attract talent. In general, employees appreciate being able to telework and this contributes to a positive workplace. The Office is also planning to reduce its physical space requirements as fewer employees will need to be accommodated on-site. To continue to address matters of importance across the federal public sector and elsewhere, the Office has created two cross-divisional working groups. One is focused on Equity, Diversity and Inclusion and aims to apply the concepts that harness the strengths of a diverse workforce. The other is focused on Learning and Development and aims to equip employees with the tools and skills that are required to efficiently fulfill the Office's mandate. The Office has started taking steps to implement Bill C-81, An Act to ensure a barrier-free Canada. This legislation will benefit all Canadians, and especially persons with disabilities, by preventing barriers in areas like information and communications technologies. The Office refined and started implementing a comprehensive plan to strengthen and expand internal communications. Strong internal communications can build employee engagement. They can help ensure employees' well-being by contributing to their mental health, motivation and happiness. And they can drive operational excellence, by ensuring all employees have the information they need to do their jobs, helping them see the big picture and how their work supports it, and making them feel invested in the organization. Internal communications are also especially important in a telework or hybrid environment. In February 2022, the Office launched a new intranet, a collaborative hub that enables employees to easily access the internal information and resources they need to do their jobs effectively and eliminate potential duplication of effort. It reflects a key focus area of the Office's strategic plan: establishing efficient, accessible and user-friendly information and data management systems. It also contributes to the goal of ensuring an engaged, collaborative, healthy, inclusive and diverse workforce. The Office updated its employee orientation guide to better support onboarding. It created a new tool to improve collaboration among employees by providing ideas and approaches for handling new types of cases that may not fall within pre-set processes, suggesting questions that employees should ask themselves to help guide them and providing a list of internal contacts, categorized by file, to help them find the answers they need. The Office also linked employee awards to specific competencies by developing an updated awards and recognition program that aligns with the Office's Code of Values and Standards of Conduct. To ensure the Office's policy framework reflects current realities, the Office developed and implemented a Policy on COVID-19 Vaccination and a Work Place Harassment and Violence Prevention Policy. It also published a Pay Equity Act notice signalling its intent to post a pay equity plan by the legislated deadline of August 31, 2024, and to update it. The Workplace Harassment and Violence Prevention Policy, which took effect in May 2021, was established to meet the requirements of the Parliamentary Employment and Staff Relations Act regarding the Canada Labour Code, Part II, and its Work Place Harassment and Violence Prevention Regulations. It applies to all employees of the Office, as well as to every person granted access to the work place. This includes the Office's premises at 66 Slater Street in Ottawa, or any location or any event related to work activities, including while working remotely/from home in accordance with an employer-approved telework arrangement. As required by the policy, the Office conducted an assessment of internal and external risk factors to target any hazards specific to the Office that could contribute to harassment and violence in the work place. While the assessment showed that many measures were already in place to mitigate identified risks, the Office developed some additional measures. The Office held a mandatory information session on the policy for all employees, made related resources available on its intranet and required all employees and managers to take relevant training. Going forward, all new employees must complete training on workplace harassment and violence prevention within three months of their start date. ​ ​ Commissioner's Office 4 employees ​ ​ Advisory and Compliance 21 employees Investigations a​nd Legal Services 7 employees Communications, Outreach and Planning 9 employees Corporate Management 11 employees ​No employees left the Office in 2021-2022. While turnover among Office employees has historically been quite low, it appears t​o have stalled during the COVID-19 pandemic, possibly because of uncertainties in the external environment. By comparison, four employees (8.7%) left the Office in 2019-2020 and two (4.2%) left in 2020-2021. As an organization of just over 50 employees, the Office recognizes that its small size has some benefits. These include being nimble so it can respond quickly to changes in the external environment and being able to quickly and easily draw on expertise from throughout the organization to address emerging issues and priorities. However, it is also aware of potential challenges, such as the need for employees to have multiple skill sets. This can make it difficult to staff positions, creates additional training requirements, makes it harder for other employees to cover the duties of absent colleagues, and reduces opportunities to meet succession planning needs from within the organization. As well, in small organizations, internal views may be prioritized and there may be fewer opportunities to seek input and opinions from outside the organization. There are also fewer professional development and career development opportunities. The Office is working to address these challenges on several fronts. In addition to actions mentioned elsewhere in this report, it is identifying training opportunities for employees, encouraging them to join communities of practice that bring together individuals from federal departments and agencies, and monitoring international counterparts for new and innovative ideas. Our infrastructure The Office continued to update its policies and guidelines in line with those of other parliamentary entities and the wider public service. To make internal operations more efficient, its Corporate Management division implemented a new document management system and a new human resources management system. It also updated a suite of financial policies that will take effect in the new fiscal year. The Office's financial statements are audited each year by an independent external auditor. The Financial Resources Summary appended to this report outlines its financial information for the 2021-2022 fiscal year. To better serve regulatees and the public and to improve internal administrative processes, in 2021-2022 the Office undertook the most significant information technology project in its history. With support from House of Commons IT staff, it began developing a new, integrated system that will replace the declaration portal, the public registry and the Office's internal case management system when it launches in fiscal year 2022-2023. This all-in-one platform will give reporting public office holders a fully secure, fast and easy way to submit to the Office information required under the Conflict of Interest Act, communicate with their advisors, keep track of their compliance requirements and request reimbursement of blind trust fees. It will give public office holders who do not have reporting obligations a more convenient way of communicating with the Office. It will give the Office a more accurate and more efficient means of managing regulatees' files. And it will enhance the usefulness of the public registry by helping to ensure the timeliness and accuracy of postings. Our plan The Office has put in place a three-year strategic plan that captures the Commissioner's vision and is designed to improve the way it fulfills its mandate in the 2021-2024 period. Not only does the plan identify a number of projects, the Office also strives to align other projects to the key focus areas identified in it to ensure that resources are adequately harnessed. Many of the initiatives mentioned in this report align with one of those key focus areas along with the projects that were completed: Stakeholder communications and engagement Key Stakeholder List, Public Office Holder Survey, tailored educational activities People and culture New policies and guidelines, working groups on Equity, Diversity and Inclusion, and on Learning and Development Information management New collaborative tools and records management, new intranet Information technology​ Work on the new software for managing public office holders and Members of the House of Commons Approach to compliance assurance Analysis of public sources to ensure compliance, review of the Act and the Code exercises The strategic plan is an evergreen tool. The status of all projects identified in it was assessed quarterly and the results shared with senior management, allowing for some timelines to be redefined based on changing operational needs while ensuring continued progress towards their completion. ​ Our c​​hallenges The Commissioner sees challenges as opportunities that carry the potential for positive change. Leveraging technology Responding to the​ workplace challenges caused by the COVID-19 pandemic was an opportunity for the Office to improve and streamline how it operates on a day-to-day basis. Forced to rethink many of its work processes, it has embraced collaborative tools and new technology that can save time by making processes more efficient and enable employees to work together more effectively. Time saved can be spent on other activities that support the achievement of the Office's mandate, such as information gathering and strategic analysis. Technology is now at a point where it is reliable, user-friendly and convenient. The Office is leveraging these tools, while prudently balancing the risks of relying on automated processes. In 2021-2022, the Office built on its efforts in recent years to streamline and improve processes by using technology in new ways. For example, since April 2021, production of its quarterly statistical reports, which were previously created manually using input from the Office's different divisions, is now 80% automated. Thanks to advancements in collaboration technology, the tools and software used have been tailored to significantly reduce the need for manual input, avoiding human error and speeding up the task. This leaves more time for the analytical thinking that translates into meaningful observations that can inform decision making. Using technology to improve other internal processes has positively impacted regulatees by streamlining the Office's interactions with them. The Office's 2021-2024 strategic plan has a component that focuses on building for the future. In support of this forward-looking approach, the Office is developing a new, integrated system that will replace the declaration portal, the public registry and the Office's internal case management system. (For more information, please see “Our Infrastructure" section.) This recalls the theme of the 2019 OECD Anti-Corruption and Integrity Forum, “Tech for trust." Examining the relationship between technology and democracy, the forum focused on the risks and opportunities afforded by new technologies and demonstrated that, with the proper tools, conflicts of interest could be effectively prevented and managed using technology. Declining public trust The 2022 Edelman Trust Barometer and Transparency International's 2021 Corruption Perceptions Index both indicated declining levels of public trust in governments and institutions in democracies around the world, including Canada. By helping regulatees avoid and prevent conflicts between public and private interests, the Office plays an important role in contributing to Canadians' trust in public officials and the institutions in which they serve. Indeed, one of the purposes of the Conflict of Interest Act is to "minimize the possibility of conflicts arising between the private interests and public duties of public office holders and provide for the resolution of those conflicts in the public interest should they arise." Similarly, one of the purposes of the Conflict of Interest Code for the House of Commons is 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." Transparency is also key. In recent years, the Office has taken steps to make its administration of Canada's federal conflict of interest regimes as transparent as possible. It posts information in the public registry in a timely manner, provides as much information as the regimes allow when responding to requests for information from the media and others, publishes quarterly statistical reports on its activities, issues regular updates of the Members' Compliance Status Report and draws attention to the public registry through tweets and presentations. It has also started to focus on using plain language in its communications to help the public better understand the federal ethics framework. The Office will continue to develop this aspect of its mandate to help inform Canadians' opinions about the state of institutions and democracy in Canada. Court matters Matters involving the Office have been the object of several applications for judicial review. While dealing with them can consume a significant amount of resources, they can also be opportunities to clarify the Commissioner's mandate and powers. One court matter was resolved in 2021-2022: Democracy Watch v. Attorney General of Canada, 2021 FCA 133: Democracy Watch applied for a judicial review of the Commissioner's decision in the Trudeau II Report. The Commissioner had commenced an examination in relation to allegations that the Prime Minister had used his position to unduly influence the Attorney General of Canada in a criminal proceeding. The applicant alleged that the Commissioner fettered his discretion and unreasonably refused to exercise his jurisdiction under the Act when he stated he did not have reasonable grounds to pursue concurrent examinations of eight public office holders who acted under the direction or authority of the Prime Minister. In dismissing the application, the Federal Court of Appeal held that the Commissioner's decision not to commence concurrent examinations was not a reviewable matter because it did not affect rights, impose legal obligations or cause prejudicial effects to those eight public office holders. Only one court matter is outstanding as of March 31, 2022: Democracy Watch v. Attorney General of Canada (A-169-21): Democracy Watch is challenging the findings of the Commissioner's Trudeau III Report. Specifically, Democracy Watch alleged in its notice of application that the Commissioner twice erred in law, erred in fact and violated a rule of natural justice. In support of its application, Democracy Watch requested a certified copy of all relevant documents related to the Commissioner's examination. The Commissioner objected to Democracy Watch's request for the certified tribunal record, noting that the record is not relevant to establish, validate or support any of those grounds. The Attorney General of Canada also filed a motion to strike the application on August 20, 2021. The Federal Court of Appeal has not yet rendered its decision on the motion.​ Appendix Financial resources summary ​(thousands of dollars) Program Activity ​2020-2021 Actual Spending 2021-2022 Alignment toGovernment of CanadaOutcomes​ ​Main Estimates ​Total Authorities ​Actual Spending ​Administration of the Conflict o​f Interest Code for Members of the House of Commons and the Conflict of Interest Act​​ 6,305 6,853 6,853 6,568 ​Government Affairs​Contributi​ons to employee benefit plans​756817817​771​​Total spending​7,061​​7,6707,670​7,339​​​​​​​​​Plus: cost of services received without charge​1,127​n/a​n/a​1,141​ Net cost of department ​8,188​7,670​7,670​8,4​80​ The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on the Office's effectiveness, management and operations, together with 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 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 my 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, 2022, 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, Mario DionConflict of Interest and Ethics Commissioner 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 2021-2022. Throughout the year, the Office helped Members of the House of Commons achieve and maintain compliance with the Code, gave them confidential guidance tailored to their individual situations, and helped them understand their obligations. After the September 2021 election, we helped new and re-elected Members complete the initial compliance process under the Code. Prevention is the major focus of the regimes the Office administers, and in the past year we strengthened education initiatives to help prevent conflicts of interest. The Office supports, advises and directs Members, and monitors their actions. However, it is up to all Members to take the time to learn about the conflict of interest rules and develop a reflex to act ethically. In the area of enforcement, we reported on one inquiry under the Code. I was pleased to appear before the House of Commons Standing Committee on Procedure and House Affairs during its review of the Code and to present and discuss my recommended changes. We were also busy in other key activity areas. The volume of compliance work with regulatees increased by over 40% compared to the previous year. The Office supported transparency by maintaining the public registry and publishing quarterly statistical reports on its activities. We educated and informed Canadians about the conflict of interest regimes and the Office's work. We further grew the ​Office's social media presence. We also continued to work with our Canadian and international counterparts. I passed the mid-point of my seven-year term as Commissioner in 2021-2022. This was an opportune time to take stock of the processes and procedures that are in place to support the achievement of our mission. The Office has evolved into a mature organization, and I believe our approach to compliance assurance has proven effective and efficient. ​I remain honoured to serve Parliament and Canadians and am grateful to the employees of the Office for helping me fulfill my mandate. Our vision​ Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament.​ Our mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.​​ Our stakeholders The Office's stakeholders include regulatees—the individuals subject to the conflict of interest regimes it administers—as well as Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report touches on all stakeholder groups, but its focus is the Members of the House of Commons who are subject to the Conflict of Interest Code for Members of the House of Commons. Members are key stakeholders of the Office. One of the Office's strategic objectives is to increase trust in and credibility of the Office with key stakeholders so that they become stronger allies in the delivery of its mandate and can effectively manage conflict of interest issues. The Commissioner is also mandated under section 32 of the Code to undertake educational activities for Members regarding the Code and the role of the Commissioner. Indeed, one of his recommendations to the House of Commons Standing Committee on Procedure and House Affairs regarding possible amendments to the Code was to establish mandatory training for Members on its principles and requirements. (Please see “Reporting to Parliament​" section.) In support of stakeholder communications and engagement, a key focus area of the Office's 2021-2024 strategic plan, the Office updated its list of stakeholders to allow for timely, proactive and fine-tuned messaging. An important purpose of this project was to assess regulatees' individual needs to help improve education, outreach and service delivery. As part of this project, it identified a new category of stakeholders dubbed “accelerators." These are entities or groups that are not subject to the Conflict of Interest Code for Members of the House of Commons or the Conflict of Interest Act but play a role in educational activities for regulatees. By engaging more actively with accelerators, the Office can better adapt its outreach and education activities to the needs of regulatees. For example, when the Office organized two educational sessions for Members of the House of Commons in November 2021, it also invited their staff. That is because even though Members' staff are not subject to the Code, they can help Members with their compliance. More important, the actions or conduct of Members' staff may positively or negatively impact the public perception of the integrity of Members and their office, which is the first of the four purposes of the Code. The Office's quarterly statistical reports provide an accurate reflection of the fluctuations that occur throughout the year. There was a general election in September 2021. When Parliament is dissolved, triggering a general election, Members of the House of Commons are no longer considered Members. They are also no longer subject to the Conflict of Interest Code for Members of the House of Commons so their information is removed from the public registry until, if re-elected, their initial compliance process is completed. Elections generate high work volumes for the Office. After a general election, it must guide all 338 Members, whether elected for the first time or re-elected, through the initial compliance process, advise them on meeting ongoing reporting requirements, post their information in the public registry and update internal records. These activities support Members in achieving and maintaining compliance with the Code during their time in office. The following graph provides a snapshot of Members on March 31, 2022. Members of the House of Commons (338)​ Ministers*12%Parliamentary secretaries*​12%Members of the House of Commons who are not ministers or parliamentary secretaries​76% *also subject to the Conflict of Interest Act Our achievements Key activities Reporting to Parliament​​Reporting to Parliament and testifying before its committees​​Compliance​Helping regulatees achieve and maintain compliance with the conflict of interest regimes​Direction and adviceGiving regulatees confidential guidance tailored to their individual situations​​​Education and outreach​Helping regulatees understand their obligations under the regimesEnforcement​Applying investigation and other enforcement provisions of the regimes as appropriate​​Public communications​​Educating and informing regulatees, the media and the general public​Collaboration and best practicesExchanging information with domestic and international counterparts Reporting to Parliament​ As an Officer of the House of Commons, the Conflict of Interest and Ethics Commissioner has a duty to report to Parliament, testify before parliamentary committees and respond to requests from Parliament. The Commissioner takes this duty very seriously and makes fulfilling it a top priority. Reflecting the Commissioner's independence, he reports on behalf of Canadians to Parliament directly, not through a minister. He submits his reports under the Conflict of Interest Code for Members of the House of Commons to the Speaker of the House of Commons, who tables them in the House. The Commissioner reports on inquiries under the Code to the House of Commons. He submits a list of sponsored travel under the Code to the Speaker by March 31 each year. 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 2021 List of Sponsored Travel was tabled in the House of Commons on March 3, 2022. The number of sponsored trips accepted by Members was very low for the second year in a row in comparison to the pre-pandemic yearly average. They reported just seven trips in 2021 compared to an average of 83 between 2007, when the Office started publishing the List of Sponsored Travel, and 2019. By June 30 each year, the Commissioner submits an annual report on the administration of the Code to the House. The Office sends communiqués to parliamentarians when reports under the Code and the Conflict of Interest Act are tabled or released. Seven communiqués were sent in 2021-2022. The Commissioner also testifies before parliamentary committees about the Office and its work when invited to do so. On May 28, 2021, the Commissioner appe​ared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics to discuss the Office's submission for the 2021-2022 Main Estimates. The Committee has oversight responsibility for the Office and reviews its annual spending estimates, as well as matters related to the Commissioner's reports under the Act. The Commissioner reached out to the newly elected Chairs of the House of Commons Standing Committee on Procedure and House Affairs and Standing Committee on Access to Information, Privacy and Ethics to welcome them to the position and to offer a meeting. On December 14, 2021, the Commissioner appe​ared before the House of Commons Standing Committee on Procedure and House Affairs, which has responsibility for the Code. Invited to discuss the Code, the Commissioner also indicated that if the Committee decided to undertake a comprehensive review of the Code, he would be pleased to participate. The Committee launched a review of the Code and invited the Commissioner to its first meeting on the review. On February 3, 2022, the Commissioner appeared before it to discuss his recommended changes to the Code. A written submission to the Committee details six recommendations: ​Establish an exemption from the Code's acceptability test to allow Members to accept all gifts or other benefits of a modest amount (totalling $30 or less, all inclusive, from a single source in a 12-month period) including those from lobbyists, as these would be unlikely to present any conflict of interest.Strengthen the Code's rules of conduct against furthering the private interest of friends and family by expanding its definition of “family" to match the broader definition of family in the Members By-law, which also includes a Member's siblings, parents and in-laws.Prohibit outside activities that are incompatible with a Member's parliamentary duties and functions.Make sponsored travel subject to the Code's acceptability test for gifts or other benefits.Establish mandatory training on the Code's principles and requirements for new Members within the first 60 days after confirmation of their election, and annually for all Members.Grant the Commissioner additional autonomy to issue generalized guidelines or forms without the approval of the House of Commons Standing Committee on Procedure and House Affairs. The Code is an instrument of the House of Commons and the House has the sole authority to amend it. Whether or not any amendments result from the Committee's review, the Commissioner believes it was a worthwhile undertaking. Compliance​ In support of its mission to ensure full compliance with the conflict of interest regimes it administers, the Office devotes most of its resources to helping regulatees achieve and maintain compliance with them. The Office identified a preventative approach to compliance assurance as a key area of focus in its 2021-2024 strategic plan. It involves providing regulatees with proactive guidance, including direction on issues involving real or potential conflicts of interests. It includes offering annual training for Members who are ministers or parliamentary secretaries to strengthen their ability to identify potential conflicts of interest. As part of this approach, the Office will also identify new tools to help detect potential compliance issues, at-risk activities and areas that could raise concerns. Employees in the Advisory and Compliance division guide Members through the compliance processes under the Conflict of Interest Code for Members of the House of Commons. They give them confidential advice supported by legal opinions on individual files as necessary, post their publicly declarable information in the pu​blic registry and ensure they have the information they need to understand their obligations. The Office's contact with Members starts shortly after their election or re-election and continues throughout their time in office. How does the Office help M​embers comply with the Code? ​By giving them advice when they need it605 instancesBy posting their declarable information in the public registry446 postings​​​By contacting them as soon as they are elected​338 communicationsBy ensuring they complete their initial compliance process​​255 processes​By contacting them annually​​​163 reviews​ Initial compliance process The initial compliance process is a critical step that all Members must complete to achieve compliance with the Conflict of Interest Code for Members of the House of Commons. It is an opportunity for them to learn the rules, reflect on areas where they might potentially find themselves in a conflict of interest and address potential issues. Once they have completed this process, they are well positioned to maintain their compliance with the Code throughout their time in office and thus avoid any conflict of interest. Members are welcome to contact the Office for one-on-one personal advice about their situation at any time. The initial compliance process begins soon after a Member is elected or re-elected in a general election or by-election, when their names are published in the Canada Gazette. Employees in the Advisory and Compliance division guide Members through the initial compliance process and the Commissioner is kept abreast of Members' files throughout. The Office communicates with Members in their preferred official language, as indicated by Elections Canada. Members may also inform the Office whether they wish to communicate in English or French. Helping all 338 Members complete the initial compliance process under the Code was a key focus for the Office in the months after the September 2021 general election. The Office handled this significant increase in workload by ensuring all advisory positions were staffed and streamlining some of its administrative procedures. As a result, it maintained its service level and was able to address the influx within a reasonable period of time. As of March 31, 2022, less than seven months after the election, the Office had completed its review of 90% of Members' files, with 75% of Members having finalized their initial compliance process under the Code. The Office maintains a Members' Compliance S​tatus Report that identifies where each Member is in the initial compliance process. It published an updated status report monthly following the September 2021 election. Initial compliance process for Members of the House of Commons Office sends first letter within three days of pu​blication of election in the Canada Gazette (with copy of Code and other supporting documents)​​338 first letters sent​​Member files confidential Disclos​ure Statement, no later than 60 ​days after notice of their election or re-election appears in the Canada Gazette​​​Member participates in initial compliance call with advisor from Office​53 initial compliance calls, most made to new MembersOffice sends intermediate letter with Disclosure Summary​305 inter​mediate letters sent​Member signs and returns Disclosure Summary, within 60 days​​Office sends final letter, signaling end of initial compliance process​255 final let​ters sent​Office updates public registry​255 initial compliance postingsOffice updates Members' Compliance Status Report​​​ In 2021-2022, the Office began developing a new system which in fiscal year 2022-2023 will replace the declaration portal that regulatees currently use to submit their public declarations. It will give Members a fully secure, fast and easy way to submit to the Office information required under the Code, communicate with their advisors and keep track of their compliance requirements. (Please see “Our Infrastructure" section.) Ongoing reporting requirements After completing the initial compliance process under the Conflict of Interest Code for Members of the House of Commons, Members must meet various reporting requirements throughout their time in office to maintain compliance. This is a crucial requirement because changes to their personal situations over time, as well as other developments, may create the potential for conflicts of interest to arise. When they disclose such information to the Office, advisors can help them prevent and avoid such conflicts. Within 60 days, Members must inform the Office of any material change to the information in their Disclosure Statement. This allows the Office to advise if there are any measures that must be taken and whether their Disclosure Summary needs to be amended. In 2021-2022, Members sought advice from the Office about material changes in 255 instances and publicly declared 53 material changes. In the second quarter, when the September 2021 election was called, 90% of requests for advice were about “material changes" and “general obligations," which would include questions about the role of a Member when an election is called. Ongoing reporting requirements ​​Annual review​​​​​​​163 annual ​​reviews initiated and 126 received​​Material changes​​​​​​Gifts and other benefits​​​ ​​​Sponsored travel​​Sp​onsored travel totalled $13,651.70 in calendar year 2021Private interests Public registry Making up-to-date compliance information accessible to the public contributes to transparency and enables public scrutiny; powerful tools that are key to the effectiveness of conflict of interest regimes. The Office maintains a public registry of all the information about individual public office holders and Members of the House of Commons that the Commissioner is authorized to make public. A searchable database, it is frequently accessed by regulatees, the media, members of the public, governments around the world and international ethics practitioners. Improvements to the registry are coming in fiscal year 2022-2023. It will become part of an integrated system that will include a new declaration portal and a new internal case management system, ensuring postings are timely and accurate and enhancing the user experience. However, there will be no changes to the types of information it contains. (Please see “Our Infrastructure" section.)​ In 2021-2022, the Office posted a total of 1,250​ items in the public registry, down 10% from the previous year. Contributing to this decrease was the high turnover among regulatees. This is typical of the period before and during an election call. There were over 65,000 public registry page views in 2021-2022, which is in line with the previous year. During the September 2021 election, there was a slight dip in public registry page views and activity, followed by an increase in page views and postings. The registry contains a dedicated page for each regulatee and, depending on current events, some pages are consulted more often than others. Over the past few years, there has been an overall increase in the number of public registry visits, with a significant spike in the last quarter of 2021-2022. This may reflect a higher level of interest in the Office's mandate, a better understanding of the rules that apply to regulatees and greater awareness of the registry following the election. ​ What did Members of the House​​ of Commons declare in 2021-2022? ​Disclosure summaries367​Material changes53Gifts and other benefits21​Sponsored​ travel (calendar year)​​5Private interest​s​0 ​ Direction and advice Prevention—that is, recognizing and avoiding conflict of interest situations—is a major focus of the regimes administered by the Office. Members of the House of Commons must familiarize themselves with the rules and take appropriate measures to prevent conflicts of interest. The Commissioner encourages Members to seek direction and advice from the Office when they come across situations that may be difficult for them to navigate. To ensure it meets their needs in a timely manner, the Office has put in place a service standard of three business days for responding to requests for advice. This standard was met in 95% of cases in 2021-2022, surpassing the 80% target. The Office responded to 605 requests for advice from Members of the House of Commons, up 23% from the year before. The Commissioner recognizes the importance of ensuring the confidential advice it provides to Members is clear and consistent and has made this a priority for the Office since his appointment. While there is no one-size-fits-all approach that can apply to every situation, as there may be factors that can change the outcome of a decision in cases that appear similar, the Office continues to take measures to ensure consistency. It records the Commissioner's interpretations of the Code in an internal practice manual that advisors can consult. Whenever a Member consults the Office, the consultation is added to their confidential file for future reference. This process helps advisors better understand the realities faced by Members and to continue to adapt advice and messaging to help them prevent conflicts of interest. The Commissioner also maintains an ongoing dialogue with advisors. The Office tracks the type of advice requested to establish trends that may impact its workload and identify training needs. After an educational session that the Commissioner hosted for new Members in November 2021, there was a 40% increase in requests for advice from Members within the same quarter. What did Members of the House of Commons ask about? Material changes42%​​General obligations36%Gifts and other benefits14%Letters of support8% Education and outreach The Commissioner has a specific mandate under section 32 of the Conflict of Interest Code for Members of the House of Commons to undertake educational activities for Members and the general public regarding the Code and the role of the Commissioner. In May 2021, the Office participated in a presentation to Members' staff to explain the Code's requirements. Although Members' staff are not subject to the Code, they are identified as “accelerators" in the key stakeholder list, because their awareness of the Code helps the Office achieve its mandate. In November 2021, the Commissioner participated in two educational sessions, one in each official language, for Members and their staff, reaching a total of 109 participants. The purpose was to provide an overview of the Code and answer any questions about the initial compliance process under the Code. The Office reached out to Members on Twitter (@EthicsCanada) as an additional means of helping them understand their obligations under the Code and how to comply with it. The Office also updated the list of accounts it follows to include all Members. The Office reached out to candidates in the September 2021 federal election to make them aware of some of the conflict of interest rules they would have to follow if elected to the House of Commons. The Commissioner sent an email to registered parties asking them to forward information to all their candidates, an information page for candidates was added to the Office website and tweets targeting candidates and linking to that page were issued. These actions aimed to encourage new Members to keep their obligations under the Code top of mind after their election. This outreach prompted over 700 page views of the candidates page, generating over 2% of the website traffic during the election period. Enforcement The Commissioner can conduct inquiries of possible contraventions of the Conflict of Interest Code for Members of the House of Commons and the inquiry reports are made public. Any Member who has reasonable grounds to believe that another Member has contravened the Code may ask the Commissioner to investigate by submitting a signed written request that identifies the alleged non-compliance and sets out reasonable grounds for the belief that the Code has been contravened. When the Office receives a valid request for an inquiry from a Member, it must forward it without delay to the Member named in the request and give them 30 days to respond. After receiving their response, the Commissioner conducts a preliminary review to determine if an inquiry is warranted. Within 15 working days of receiving the response, the originator of the request and the Member named in it are notified of the Commissioner's decision as to whether an inquiry will be conducted. Under paragraph 27(5.1)(iii) of the Code, the reasons for not proceeding with an inquiry may be described if the matter to which the inquiry relates has already been made public. The House of Commons may also direct the Commissioner, by way of resolution, to conduct an inquiry, although this has not yet occurred since the Code was adopted in 2004. The Commissioner also has the discretion to conduct an inquiry on his own initiative if he has reason to believe that a Member has contravened the Code. The Commissioner may decide to do so based on information from various sources, including media reports and complaints from members of the public. Fewer than a dozen requests for investigations under the Code were received from members of the public in 2021-2022. Sanctions The Commissioner is not empowered to impose sanctions under the Code but may recommend sanctions in inquiry reports. Under section 28 of the Code, the Commissioner may recommend that the House of Commons impose appropriate sanctions following an inquiry in which the Commissioner concludes, for example, that a Member has not complied with an obligation under the Code and did not take all reasonable measures to prevent the non-compliance, or where a request for an inquiry was frivolous or vexatious or was not made in good faith. Only the House has the right to discipline its own Members and is responsible for imposing and administering sanctions, including any that may be recommended by the Commissioner. Inquiry case files When the Office receives information about a possible contravention of the Code, including through media reports or complaints from members of the public, a case file is opened. The information is reviewed to determine whether the concern raised falls within its mandate. Some of these initial reviews lead to inquiries where there are reasonable grounds to believe that a contravention of the Code has occurred. In other cases, an inquiry is not found to be warranted and the files are closed. Compared to the previous fiscal year, there was a 19% increase in case files. The Office experienced an influx of complaints that prompted case files to be opened during the second quarter, coinciding with the electoral period. Since Members of the House of Commons are no longer considered Members and thus no longer subject to the Code once a general election has been called, their requests for investigation are counted as requests from members of the general public. Following that influx, there was a sharp drop in the number of case files opened during the last two quarters. However, in February and March 2022, the Office received over 1,000 requests from members of the public asking the Commissioner to investigate the participation of Members and ministers in the World Economic Forum. Since the requests did not provide sufficient evidence to warrant an investigation and they were all related to the same topic, they were counted as a single case file by the Investigations and Legal Services division. (Please see “Media and Public Inquiries​" section.) Inquiry case files in 2021-2022 How many case files were opened and closed?​​Total case files (a case file is a concern that is reviewed by the Office)​​25​Ongoing​​5​Closed without an inquiry​19​Closed with publication of report​​1Who was the subject of each case file?​Current or former Member of the House of Commons25​Person not subject to the Code0​What was the source of these case files?​​Member of the House of Commons10​ ​Within the Office4​Member of the general public9​​Media​2​​​What was the nature of the concern?*​Furthering private interests​​16Influencing a decision or attempting to influence a decision4​Disclosure of information​4Attempt to engage in prohibited activities2​​Sponsored travel​1​​Gifts and other benefits​2​ *some case files have more than one concern​ As of March 31, 2022, the Office was not working on any active inquiry under the Code. One inquiry remains suspended. Inquiry Report In 2021-2022, the Office issued one inquiry report under the Conflict of Interest Code for Members of the House of Commons. In the Ratansi Report, issued on June 15, 2021, the Commissioner found that Ms. Yasmin Ratansi, Member of Parliament for Don Valley East, contravened section 8 of the Code by employing Ms. Zeenat Khatri, whom she publicly referred to as her sister, in her constituency office. Section 8 prohibits Members, when performing parliamentary duties and functions, from acting in any way to further their private interests or those of a member of their family, or to improperly further another person's or entity's private interests. The Commissioner determined that Ms. Ratansi had furthered Ms. Khatri's private interests within the meaning of the Code by employing Ms. Khatri in her constituency office. As Ms. Khatri was not considered a family member for the purposes of the Code, the Commissioner had to determine if those private interests were improperly furthered. While the Code does not set out the circumstances that constitute an impropriety when considering actions that may improperly further another person's private interests, the Commissioner has determined that an impropriety could include circumstances where a Member acts contrary to a rule outside the Code. In this case, he considered the Members By-law (By-law) of the House of Commons Board of Internal Economy, which governs the use of the resources provided by the House to Members for the purpose of carrying out their parliamentary functions. The By-law prohibits a Member from hiring members of their immediate family, including a brother or sister. The evidence showed that while Ms. Ratansi had always considered Ms. Khatri her sister and publicly referred to her as such, Ms. Khatri is in fact her foster sister. However, the public perception of Ms. Ratansi's family relationship to Ms. Khatri, based on Ms. Ratansi's own public statements and actions, led nonetheless to the strong appearance of an employment relationship that was contrary to the By-law. The Commissioner used his discretion under section 3.1 of the Code to take into consideration its purposes and principles in deciding whether the rules of conduct had been contravened in a particular case. Principles 2(b) and (c) state that Members are expected to avoid real or apparent conflicts of interests and to perform their official duties and functions in a manner that bears the closest public scrutiny, an obligation that may not be fully discharged by simply acting within the law. Taking these principles into account, the Commissioner found that the appearance that a Member has contravened a rule outside the Code can, in certain circumstances, lead to an impropriety for the purpose of section 8. Having found that Ms. Ratansi furthered Ms. Khatri's private interest by hiring her to work in her constituency office, and that she did so improperly because of the appearance of an employment relationship that contravened the By‑law, the Commissioner determined that Ms. Ratansi contravened section 8 of the Code. Barring exceptional circumstances, the Office's target is to conduct inquiries within a 12-month timeframe. Since the Commissioner took office in 2018, seven reports have been published under the Code. The average time to complete an inquiry is just over five months. The Office makes it a priority to produce inquiry reports with due dispatch to ensure that Canadians are well informed in a timely manner of any transgression to the Code, especially when the matter has been made public. To complete inquiries within a reasonable timeframe, the Office relies on the cooperation of the subject of the inquiry and other witnesses. Public communications In support of public education about the regimes that it administers, the Office makes a range of information available on its website, is active on social media, responds to inquiries from the media and members of the public, and delivers presentations to the interested public. Below is a summary of its activities in these areas for 2021-2022. The Office monitors the volume of relevant Twitter mentions, news mentions, website activity and mentions during Question Period. In general, high mentions lead to workload increases for the Office. Tracking these trends can help the Office prepare for an influx of public and media inquiries, for example, or become aware of issues that might relate to its work. The Office publishes this data in its quarterly statistical reports. Website The Office continued to maintain its website as an important source of information to help educate and inform regulatees, the media and the public. The number of website visitors increased by 19%, for a total of 52,765 visitors. In July 2021, it added to the website a detailed y that highlights milestones—dating back almost to Confederation—in the development of Canada's federal conflict of interest regimes and their administration. The chronology is a useful research tool that brings together information from a range of sources and details how the culture of ethics and integrity has been shaped in Canada.​ Social media The Office's Twitter presence allows it to be aware of and participate in relevant discussions and provides an additional source of public information about the Office and the public registry. The Office continued to be active on social media. The total number of followers for @EthicsCanada and @EthiqueCanada grew by 16% (3,596 followers), further increasing the Office's social media reach. It tweeted 159% more times than in the previous year, sending one to two tweets per day. More than 6% of visits to the Office's website were from links on Twitter and the Office's own tweets drove 2% of the traffic. Over half of the Office website's traffic resulted from an Internet search. Although difficult to pinpoint, Twitter conversations relating to ethics can lead to independent searches of the Office website to verify facts or find more information. Twitter is a preferred tool used by the media, who have been identified as key stakeholders of the Office. The Office's tweets can help them report accurately on the Office and its work. When the Office releases a report, its associated tweets often attract attention that may lead to additional inquiries from the public and the media. Media and public inquiries The Office fielded nearly 3,500 information requests received from the media and members of the public by phone, email, post and fax, as well as through direct messages on Twitter. The Communications, Outreach and Planning division has developed procedures and processes to ensure that it provides accurate, timely and useful information to the individuals and groups seeking information. Although the conflict of interest regimes' strict confidentiality provisions mean no information can be provided about individual cases, the Office strives to provide as much information as possible about the rules and their general application. The Office was also copied on a number of emails that were not relevant to its mandate. Its practice is to respond only to those that are directly addressed to the Office. Such emails represented 60% of total correspondence received in 2021-2022. The media can help the Office provide accurate information to the public about the conflict of interest regimes that it administers. In 2021-2022, the Office received 47% fewer requests from the media compared to the previous year. Many of those requests sought information about the Trudeau III and Morneau II reports and were received in the months preceding their May 2021 release. Direct inquiries about the status of a current case file or public office holder constituted 80% of media requests. Only 20% related to general inquiries about the role and mandate of the Office. Journalists have demonstrated an increased understanding of the regimes, which may have resulted in fewer requests for information about general topics. The Office met its four-hour service standard for responding to media inquiries in 100% of cases. The Office started categorizing by subject the information requests it receives, to see if any trends could be observed. For example, does an increase in media inquiries about a particular topic prompt more requests about it from members of the public and from public office holders seeking advice? This kind of information helps the Office adapt its education and outreach activities as appropriate. For example, there were several general inquiries about regulatees' general obligations, gifts, post-employment and outside activities, all of which align with the categories the Office tracks when it provides advice to regulatees. The Office consequently tweeted about these subjects to help educate the public. The data also revealed that 15% of media requests received in the past year related to ongoing public investigations while 65% were direct inquiries about a regulatee's compliance. Because of confidentiality restrictions, the Office cannot provide any information about individual regulatees other than what is already in the public registry. The Office provides additional context about the administration of the Act and the Code when possible. Just over a third of public inquiries were complaints about various subjects. The Office generally cannot act on these complaints, because they are either outside of its mandate or there are no reasonable grounds to believe a contravention has occurred based on the information received in the query. When relevant, complainants are asked to fill out an investigation request form. If they submit a completed form, the Office notifies them that their information will be reviewed. Over 1,000 of the public and media inquiries received by the Office in fiscal year 2021-2022 were from members of the public asking the Commissioner to investigate the involvement of Canadian parliamentarians in the World Economic Forum. These requests were received in February and March 2022. The Communications, Outreach and Planning division responded on behalf of the Office to each one by explaining the mandate and role of the Office and providing information about the investigation process. The responses were tracked in its public inquiry statistics. In the first quarter of the fiscal year, the Office achieved its service standard for responding to public inquiries within 10 days at 80%. Although this met the threshold set by the Office, an analysis of the response process revealed there were some efficiencies to be gained so it was changed slightly. The Office was subsequently able to achieve its service standard at higher rates, ending the year with 89% achievement of its 10-day service standard. Collaboration and best practices Thanks in part to the technology that makes it possible to have productive and effective meetings virtually, the Office continued to maintain and strengthen connections with officials and organizations in Canada and other countries in 2021-2022. Domestic outreach The Commissioner participated in the annual meeting of the Canadian Conflict of Interest Network (CCOIN) in September 2021 and in its semi-annual meeting in March 2022. CCOIN is made up of federal, provincial and territorial conflict of interest commissioners. The Office coordinates information sharing within the network, gathering and disseminating information and materials acquired by or developed in various Canadian jurisdictions. Several Canadian universities asked the Office to provide an overview of the Commissioner's role and mandate to give students an opportunity to gain a firsthand understanding of Canada's federal conflict of interest regimes. The Commissioner delivered a presentation at Carleton University, and at York University alongside Information Commissioner Caroline Maynard. In July 2021, the Commissioner participated in Quebec Ethics Commissioner Ariane Mignolet's podcast with Senate Ethics Officer Pierre Legault. They discussed conflict of interest and ethics jurisdictions across Canada and the benefits of belonging to networks of ethics practitioners. In February 2022, the Office submitted comments on the draft update of the Lobb​yists' Code of Conduct during a consultation process initiated by Commissioner of Lobbying Nancy Bélanger. Participating in this process aligned with the principles of the Memorandum of Understanding signed by the two commissioners i​n M​arch 2018. ​​ The Commissioner met privately with other agents of Parliament to discuss common issues and concerns, and Office employees liaised with their counterparts in those agents' offices. International outreach The Office always considers the value added to its mandate when it agrees to participate in international events. Sharing best practices, learning about the ways conflict of interest rules are applied and listening to the public discourse around ethics issues in other jurisdictions are part of ongoing developmental activities for members of the Office. As the field of public ethics continues to change and grow, keeping abreast of ongoing developments can help inform the Office's work. The Office remains an active member of the Réseau francophone d'éthique et de déontologie parlementaires (RFEDP) [link in French only] within the Organisation internationale de la Francophonie. The RFEDP fosters the sharing of best practices to enhance expertise and help the parliaments of Francophonie member countries adopt ethics principles and conflict of interest rules. In 2021-2022, the Office contributed to two RFEDP working groups focused on training and best practices. In November, the Commissioner and several other members of the Office participated in the RFEDP's two-day annual general meeting and the Director of Advisory and Compliance was nominated to its Bureau. The Office also continues to be an active member of the Council on Governmental Ethics Laws (COGEL), a U.S.-based international not-for-profit organization of government ethics practitioners in which other Canadian conflict of interest and integrity offices also participate. In December, the Commissioner and Office representatives attended COGEL's virtual annual conference. The Director of Communications, Outreach and Planning is a member of the program planning committee for COGEL's 2022 conference, an in-person event that will be held in Montreal in December. International outreach activities in 2021-2022 included participation by the Commissioner and other senior Office representatives in bilateral meetings with international counterparts to discuss Canada's ethics regimes and share best practices, and in other events. The Office also responded to several requests for information from or on behalf of international organizations. In September 2021, communications methods and tools were discussed with France's Haute Autorité pour la Transparence de la vie publique. In October, the Office met with the Public Sector Directorate of the Organisation for Economic Co-operation and Development (OECD) to answer its questions about best practices that could be implemented by the Office of the Commissioner for Standards in Public Life in Malta. In November, the Commissioner participated in a panel at the one-day conference on ethical standards in government organized by the United Kingdom's Institute of Government. The panel was entitled “What can the UK learn from how other governments uphold standards?" Commissioner Dion participated alongside the Director of Policy Transparency International UK and the Commissioner for Standards at the Northern Ireland Assembly. The invitation to this event resulted from the Commissioner's March 2021 appearance before the United Kingdom's independent Committee on Standards in Public Life to discuss how Canada's federal ethics regimes work. That same month, the Office sent comments on the Third Resolution for the 9th Session of the Conference of the States Parties to the United Nations Convention Against Corruption through Global Affairs Canada. The resolution, “Enhancing the use of beneficial ownership information to facilitate the identification, recovery and return of proceeds of crime," seeks to address asset recovery. In December, the Office was approached by the Treasury Board of Canada to provide input into the OECD's integrity indicators. Its input related to reporting requirements of appointed and elected public officials and general information about Canada's federal conflict of interest regimes. This project was part of the OECD Public Int​egrity Indicators Portal, which will compile data to provide an accurate picture of the state of public integrity among OECD countries. The Office will monitor the portal, which will provide access to comparative data for benchmarking purposes. In February 2022, it shared information about Canada's public integrity framework with representatives of Israel's Ministry of Justice. Finally, in March, Office representatives attended the OECD's Global Anti-Corruption and Integrity Forum. The theme was “Renew governance, business, finance, sustainability, development aid, taxation and more, with integrity." When approached, the Office is pleased to share best practices relating to the administration of the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. In March 2022, the Commissioner met with the Honourable Stéphane Dion, Ambassador to Germany and Special Envoy to the European Union, to discuss sharing best practices with the Office's counterparts in Armenia. Later that month, it was contacted by the Embassy of Mongolia and agreed to meet with its counterparts in Mongolia. Future meetings may take place during the next fiscal year. Our tools The Office's accomplishments result from the hard work, dedication and resilience of its employees in implementing the Commissioner's vision, with the support of a sound internal management framework. Our people To ensure the Office has the human resources it needs to fulfill its vision and achieve its mission, two staffing processes were completed or initiated in 2021-2022. The Office continued to operate primarily in a telework environment. It developed a new telework policy that will take effect in the new fiscal year. Under it, the Office will adopt a hybrid model where employees may choose, in consultation with their director, to work from home some or all of the time, while continuing to ensure the Office delivers on its mandate. The flexibility this approach has given employees can help them achieve a better work-life balance and reduce stress, thereby helping the Office retain and attract talent. In general, employees appreciate being able to telework and this contributes to a positive workplace. The Office is also planning to reduce its physical space requirements as fewer employees will need to be accommodated on-site. To continue to address matters of importance across the federal public sector and elsewhere, the Office has created two cross-divisional working groups. One is focused on Equity, Diversity and Inclusion and aims to apply the concepts that harness the strengths of a diverse workforce. The other is focused on Learning and Development and aims to equip employees with the tools and skills that are required to efficiently fulfill the Office's mandate. The Office has started taking steps to implement Bill C-81, An Act to ensure a barrier-free Canada. This legislation will benefit all Canadians, and especially persons with disabilities, by preventing barriers in areas like information and communications technologies. The Office refined and started implementing a comprehensive plan to strengthen and expand internal communications. Strong internal communications can build employee engagement. They can help ensure employees' well-being by contributing to their mental health, motivation and happiness. And they can drive operational excellence, by ensuring all employees have the information they need to do their jobs, helping them see the big picture and how their work supports it, and making them feel invested in the organization. Internal communications are also especially important in a telework or hybrid environment. In February 2022, the Office launched a new intranet, a collaborative hub that enables employees to easily access the internal information and resources they need to do their jobs effectively and eliminate potential duplication of effort. It reflects a key focus area of the Office's strategic plan—establishing efficient, accessible and user-friendly information and data management systems—and contributes to the goal of ensuring an engaged, collaborative, healthy, inclusive and diverse workforce. The Office updated its employee orientation guide to better support onboarding. It created a new tool to improve collaboration among employees by providing ideas and approaches for handling new types of cases that may not fall within pre-set processes, suggesting questions that employees should ask themselves to help guide them and providing a list of internal contacts, categorized by file, to help them find the answers they need. The Office also linked employee awards to specific competencies by developing an updated awards and recognition program that aligns with the Office's Code of Values and Standards of Conduct. To ensure the Office's policy framework reflects current realities, the Office developed and implemented a Policy on COVID-19 Vaccination and a Work Place Harassment and Violence Prevention Policy. It also published a Pay Equity Act notice signalling its intent to post a pay equity plan by the legislated deadline of August 31, 2024, and to update it. The Workplace Harassment and Violence Prevention Policy, which took effect in May 2021, was established to meet the requirements of the Parliamentary Employment and Sta​ff Relations Act regarding the Canada Labour Code, Part II, and its Work Place Harassment and Violence Prevention Regulations. It applies to all employees of the Office, as well as to every person granted access to the work place. This includes the Office's premises at 66 Slater Street in Ottawa, or any location or any event related to work activities, including while working remotely/from home in accordance with an employer-approved telework arrangement. As required by the policy, the Office conducted an assessment of internal and external risk factors to target any hazards specific to the Office that could contribute to harassment and violence in the work place. While the assessment showed that many measures were already in place to mitigate identified risks, the Office developed some additional measures. The Office held a mandatory information session on the policy for all employees, made related resources available on its intranet and required all employees and managers to take relevant training. Going forward, all new employees must complete training on workplace harassment and violence prevention within three months of their start date. ​ Commissioner's Office 4 employees Advisory and Compliance 21 employees Investigations and Legal Services 7 employees Communications, Outreach and Planning 9 employees Corporate Management 11 employees No employees left the Office in 2021-2022. While turnover among Office employees has historically been quite low, it appears to have stalled during the COVID-19 pandemic, possibly because of uncertainties in the external environment. By comparison, four employees (8.7%) left the Office in 2019-2020 and two (4.2%) left in 2020-2021. As an organization of just over 50 employees, the Office recognizes that its small size has some benefits. These include being nimble so it can respond quickly to changes in the external environment and being able to quickly and easily draw on expertise from throughout the organization to address emerging issues and priorities. However, it is also aware of potential challenges, such as the need for employees to have multiple skill sets. This can make it difficult to staff positions, creates additional training requirements, makes it harder for other employees to cover the duties of absent colleagues, and reduces opportunities to meet succession planning needs from within the organization. As well, in small organizations, internal views may be prioritized and there may be fewer opportunities to seek input and opinions from outside the organization. There are also fewer professional development and career development opportunities. The Office is working to address these challenges on several fronts. In addition to actions mentioned elsewhere in this report, it is identifying training opportunities for employees, encouraging them to join communities of practice that bring together individuals from federal departments and agencies, and monitoring international counterparts for new and innovative ideas. Our infrastructure The Office continued to update its policies and guidelines in line with those of other parliamentary entities and the wider public service. To make internal operations more efficient, its Corporate Management division implemented a new document management system and a new human resources management system. It also updated a suite of financial policies that will take effect in the new fiscal year. The Office's financial statements are audited each year by an independent external auditor. The Financial Resources Summary appended to this report outlines its financial information for the 2021-2022 fiscal year. To better serve regulatees and the public and to improve internal administrative processes, in 2021-2022 the Office undertook the most significant information technology project in its history. With support from House of Commons IT staff, it began developing a new, integrated system that will replace the declaratio​n portal, the public regis​try and the Office's internal case management system when it launches in fiscal year 2022-2023. This all-in-one platform will give reporting public office holders a fully secure, fast and easy way to submit to the Office information required under the Conflict of Interest Act, communicate with their advisors, keep track of their compliance requirements and request reimbursement of blind trust fees. It will give public office holders who do not have reporting obligations a more convenient way of communicating with the Office. It will give the Office a more accurate and more efficient means of managing regulatees' files. And it will enhance the usefulness of the public registry by helping to ensure the timeliness and accuracy of postings. Our plan The Office has put in place a three-year strategic plan that captures the Commissioner's vision and is designed to improve the way it fulfills its mandate in the 2021-2024 period. Not only does the plan identify a number of projects, the Office also strives to align other projects to the key focus areas identified in it to ensure that resources are adequately harnessed. Many of the initiatives mentioned in this report align with one of those key focus areas along with the projects that were completed: Stakeholder communications and engagement Key Stakeholder List, Public Office Holder Survey, tailored educational activities​ People and culture New policies and guidelines, working groups on Equity, Diversity and Inclusion, and on Learning and Development Information management New collaborative tools and records management, new intranet Information technology Work on the new software for managing public office holders and Members of the House of Commons Approach to compliance assurance Analysis of public sources to ensure compliance, review of the Act and the Code exercises The strategic plan is an evergreen tool. The status of all projects identified in it was assessed quarterly and the results shared with senior management, allowing for some timelines to be redefined based on changing operational needs while ensuring continued progress towards their completion. Our challenges The Commissioner sees challenges as opportunities that carry the potential for positive change. Leveraging technology Responding to the workplace challenges caused by the COVID-19 pandemic was an opportunity for the Office to improve and streamline how it operates on a day-to-day basis. Forced to rethink many of its work processes, it has embraced collaborative tools and new technology that can save time by making processes more efficient and enable employees to work together more effectively. Time saved can be spent on other activities that support the achievement of the Office's mandate, such as information gathering and strategic analysis. Technology is now at a point where it is reliable, user-friendly and convenient. The Office is leveraging these tools, while prudently balancing the risks of relying on automated processes. In 2021-2022, the Office built on its efforts in recent years to streamline and improve processes by using technology in new ways. For example, since April 2021, production of its quarterly statistical reports, which were previously created manually using input from the Office's different divisions, is now 80% automated. Thanks to advancements in collaboration technology, the tools and software used have been tailored to significantly reduce the need for manual input, avoiding human error and speeding up the task. This leaves more time for the analytical thinking that translates into meaningful observations that can inform decision making. Using technology to improve other internal processes has positively impacted regulatees by streamlining the Office's interactions with them. The Office's 2021-2024 strategic plan has a component that focuses on building for the future. In support of this forward-looking approach, the Office is developing a new, integrated system that will replace the declaration portal, the public registry and the Office's internal case management system. (Please see “Our Infrastructure" section.) This recalls the theme of the 2019 OECD Anti-Corruption and Integrity Forum, “Tech for trust." Examining the relationship between technology and democracy, the forum focused on the risks and opportunities afforded by new technologies and demonstrated that, with the proper tools, conflicts of interest could be effectively prevented and managed using technology. Declining public trust The 2022 Edelman Trust Barometer and Transparency International's 2021 Corruption Perceptions Index both indicated declining levels of public trust in governments and institutions in democracies around the world, including Canada. By helping regulatees avoid and prevent conflicts between public and private interests, the Office plays an important role in contributing to Canadians' trust in public officials and the institutions in which they serve. Indeed, one of the purposes of the Conflict of Interest Act is to "minimize the possibility of conflicts arising between the private interests and public duties of public office holders and provide for the resolution of those conflicts in the public interest should they arise." Similarly, one of the purposes of the Conflict of Interest Code for the House of Commons is 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." Transparency is also key. In recent years, the Office has taken steps to make its administration of Canada's federal conflict of interest regimes as transparent as possible. It posts information in the public registry in a timely manner, provides as much information as the regimes allow when responding to requests for information from the media and others, publishes quarterly statistical reports on its activities, issues regular updates of the Members' Compliance Status Report and draws attention to the public registry through tweets and presentations. It has also started to focus on using plain language in its communications to help the public better understand the federal ethics framework. The Office will continue to develop this aspect of its mandate to help inform Canadians' opinions about the state of institutions and democracy in Canada. Court Matters Matters involving the Office have been the object of several applications for judicial review. While dealing with them can consume a significant amount of resources, they can also be opportunities to clarify the Commissioner's mandate and powers. One court matter was resolved in 2021-2022: Democracy Watch v. Attorney General of Canada, 2021 FCA 133: Democracy Watch applied for a judicial review of the Commissioner's decision in the Trudeau II Report. The Commissioner had commenced an examination in relation to allegations that the Prime Minister had used his position to unduly influence the Attorney General of Canada in a criminal proceeding. The applicant alleged that the Commissioner fettered his discretion and unreasonably refused to exercise his jurisdiction under the Act when he stated he did not have reasonable grounds to pursue concurrent examinations of eight public office holders who acted under the direction or authority of the Prime Minister. In dismissing the application, the Federal Court of Appeal held that the Commissioner's decision not to commence concurrent examinations was not a reviewable matter because it did not affect rights, impose legal obligations or cause prejudicial effects to those eight public office holders. Only one court matter is outstanding as of March 31, 2022: Democracy Watch v. Attorney General of Canada (A-169-21): Democracy Watch is challenging the findings of the Commissioner's Trudeau III Report. Specifically, Democracy Watch alleged in its notice of application that the Commissioner twice erred in law, erred in fact and violated a rule of natural justice. In support of its application, Democracy Watch requested a certified copy of all relevant documents related to the Commissioner's examination. The Commissioner objected to Democracy Watch's request for the certified tribunal record, noting that the record is not relevant to establish, validate or support any of those grounds. The Attorney General of Canada also filed a motion to strike the application on August 20, 2021. The Federal Court of Appeal has not yet rendered its decision on the motion. Appendix Financial resources summary ​​​​ ​​(thousands of dollars) ​​Program Activity 2020-2021 Actual Spending 2021-2022 Alignment toGovernment of CanadaOutcomes​ ​Main Estimates Total Authorities Actual Spending ​Administration of the Conflict o​f Interest Code for​ Members of the House of Commons and the Conflict of Interest Act​​ ​ 6,305 ​ 6,853 ​ 6,853 ​ 6,568 ​Government Affairs​Contributi​ons to employee benefit plans​756817817​771​​Total spending​7,061​​7,6707,670​7,339​​​​​​​​Plus: cost of services received without charge​1,127​n/a​n/a​1,141​​​​ ​​​Net cost of department​8,188​7,670​7,670​8,4​80​​​​​​ The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on the Office's effectiveness​, management and operations, together with 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 Mr. Speaker: I am pleased to submit to you my 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, 2021, for tabling in the Senate. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Mario Dion​Conflict of Interest and Ethics Commissioner Dear Mr. Speaker: I am pleased to submit to you my 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, 2021, 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, Mario DionConflict of Interest and Ethics Commissioner Commissioner's message I am pleased to report on the administration of the Conflict of Interest Act in 2020-2021. In response to the changes brought by the COVID-19 pandemic, we fully adapted our processes to telework and moved to electronic paperless communications with regulatees, including the annual message to public office holders without reporting obligations. Modifications to our processes and technology, coupled with the diligence and hard work of employees, enabled the Office to successfully manage a high volume of work across all activity areas in support of its vision and mission. We ended the fiscal year with no significant backlogs of work anywhere in the organization. We worked with ministers and ministerial staff to finalize their initial compliance process under the Act following the October 2019 election, while continuing to provide direction and advice to all public office holders to help them meet their obligations. We supported transparency by maintaining the public registry, publishing quarterly statistical reports on our activities and tweeting administrative monetary penalties and compliance orders. Much of the Office’s enforcement work under the Act was taken up by the examinations of the conduct of Prime Minister Justin Trudeau and former Finance Minister Bill Morneau in relation to the selection of the WE organization as the administrator of the Canada Student Service Grant. We also reported on four referrals from the Public Sector Integrity Commissioner. We were active in the area of education and public communications. We expanded our social media presence and changed our Twitter handle to @EthicsC​anada. We also engaged with our counterparts in Canada and around the world on various initiatives. Building on the work accomplished by the Office in the past three years, we developed a new three-year strategic plan to help guide our activities going forward. I remain honoured to serve Parliament and Canadians and am grateful to the employees of the Office for helping me fulfill my mandate.​ Our vision​ Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament.​ Our mission​ Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.​ Our stakeholders The Office’s stakeholders include regulatees—the individuals subject to the conflict of interest regimes it administers—as well as Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report focusses on the public office holders who are subject to the Conflict of Interest Act. As regulatees, public office holders are key stakeholders of the Office. One of its strategic objectives is to increase trust in and credibility of the Office with key stakeholders so that they become stronger allies in the delivery of its mandate and can effectively manage conflict of interest issues. Public office holders2,889 Reporting public office holders1,355 Public office holders without reporting obligations1,534 Individuals subject to the Act are collectively known as public office holders. They are all subject to the Act’s core set of conflict of interest rules (Part 1) and post-employment rules (Part 3). Just over half of these individuals (53%) are subject only to those general rules. They are referred to as “public office holders without reporting obligations.” They include part-time members of federal boards, commissions and tribunals appointed by the Governor in Council and ministerial staff who work on average less than 15 hours a week. The rest (47%) are also subject to additional rules set out in the Act (Part 2), including ongoing reporting and public disclosure provisions, and prohibitions against engaging in outside activities and holding controlled assets. They are referred to as “reporting public office holders” and include ministers and parliamentary secretaries, ministerial staff who work on average 15 hours or more a week and full-time Governor-in-Council appointees. Snapshot of public office holders on March 31, 2021 Public office holders without reporting obligations53%Reporting public office holders47% Ministerial staff26%Governor-in council appointees19%Ministers*1%Parliamentary secretaries*1% *also subject to Conflict of Interest Code for Members of the House of Commons ​Turnover in 2020-2021​​Appointed or reappointed​​Left officeReporting public office holders​264​189​Public office holders without reporting obligations​242​150 The Office’s quarterly statistical reports​ provide an accurate reflection of the fluctuations that occurred throughout the year. Compared to the previous fiscal year, there was an 8% increase in the number of individuals who were subject to the Act at the end of the 2020-2021 fiscal year. Our achievements Key activities Compliance​Helping regulatees achieve and maintain compliance with the conflict of interest regimes​Direction and advice​​Giving regulatees confidential guidance tailored to their individual situations​Education and outreach​Helping regulatees understand their obligations under the regimes​Enforcement​​Applying investigation and other enforcement provisions of the regimes as appropriate​​Public communications​Educating and informing regulatees, the media and the general public​​Collaboration and best practices​​Exchanging information with domestic and international counterparts​ ​Contacts with Parliament​Reporting to Parliament and testifying before its committees​ Compliance In support of its mission to ensure full compliance with the conflict of interest regimes that it administers, the Office devotes most of its resources to helping regulatees achieve and maintain compliance with those regimes. Reflecting one of its strategic objectives, the Office is developing a more preventive approach to compliance assurance that provides proactive guidance to regulatees, including direction on ethical issues. Employees in the Advisory and Compliance division guide public office holders through the compliance processes under the Conflict of Interest Act, give them confidential advice supported by legal opinions on individual files as necessary, post their publicly declarable information in the public registry and ensure they have the information they need to understand their obligations by delivering presentations to their organizations and hosting teleconferences. How does the Office help public office holders comply with the Act? By ensuring they complete the initial compliance process 368 processesBy giving them advice when needed 2,237 instancesBy posting declarable information in the public registry 850 postings The Office communicates frequently with reporting public office holders throughout their term of office and less often with those without reporting obligations. It aims to contact all public office holders within three days of being notified of their appointment or reappointment. In 2020-2021, this service standard was met in 80% of cases, meeting the target. When are public office holders contacted by the Office? When they are first appointed or reappointed506 communicationsOnce a year 2,374 reminders or reviewsWhen they leave office 339 communications Initial Compliance Process All reporting public office holders must complete an initial compliance process under the Conflict of Interest Act, within 120 days after their appointment or reappointment (when there is an interruption between the appointment and reappointment). As the Office guides reporting public office holders through the initial compliance process, it may establish any necessary measures under section 29 of the Act. These agreed compliance measures include the establishment of conflict of interest screens and the divestment of controlled assets. Reporting public office holders may​ not hold or acquire controlled assets during their term of office. They must divest any such assets within 120 days after their appointment, by selling them to a third party in an arm’s-length transaction or by placing them in a blind trust. In 2020-2021, there were 50 divestments of controlled assets, including 32 by sale and 18 by blind trust. The Office issues reimbursement orders to reporting public officer holders’ organizations for reasonable costs for establishing, maintaining and dismantling blind trusts. The Corporate Management division reviews and analyzes those costs as well as the costs for withdrawal of business and commission fees. It helps the Commissioner determine the reasonableness of fees incurred so reimbursement orders may be issued. In 2020-2021, the Commissioner issued 151 orders for reimbursement totalling $872,705.22. Initial compliance process for reporting public office holders First letter sent by Office (with copy of Act and summary of applicable of rules) 264 first letters sentReporting public office holder files Confidential Report within 60 days after their appointment or reappointment Office reviews Confidential Report Reporting public office holder participates in initial compliance call with advisor from Office 265 initial compliance calls madeOffice sends intermediate letter with Summary Statement and other public declarations 332 intermediate letters sentReporting public office holder signs and returns Summary Statement and other public declarations within 120 after their appointment or reappointment Commissioner sends final letter, signalling completion of initial compliance process 368 final letters sent Once the initial compliance process has been completed, the Summary Statement and any required declarations are posted in the public registry​. In 2020-2021, 368 initial compliance processes were completed and 350 summary statements were posted in the public registry. This represents a slight decrease in compliance processes completed compared to the previous year and an increase of 24% in the number of summary statements posted in the public registry. Some of those summary statements may have been part of initial compliance processes started in the previous fiscal year. Process for public office holders without reporting obligations First letter (sent with copy of Act and summary of applicable rules) 242 first letters sent Annual reminder 1,238 annual reminders sentPost-employment letter 150 post-employment letters sent Ongoing reporting requirements​ After completing the initial compliance process, reporting public office holders must meet various reporting requirements throughout their terms of office. Failure to meet some of the reporting deadlines could result in an administrative monetary penalty of up to $500. Ongoing reporting requirements Annual review 1,136 annual reviews initiated and 1,026 received Material changes Gifts or other benefits Private flights accepted by ministers and parliamentary secretaries for themselves, their families or ministerial staff Recusals Firm offers of outside employment and their acceptance 78 firm offers and acceptances disclosed ​In February 2021, the Office released an updated information notice that captures the Commissioner’s interpretation of “outside employment” referred to in section 24 of the Act. It clarifies that the term refers to employment that falls outside the scope of the Act’s substantive conflict of interest rules and only includes positions that create an employer/employee relationship. Outside employment encompasses employment with federal public sector entities as a public servant, as well as employment with a political party or with the private sector. Public registry The public registry supports transparency, a pillar of effective conflict of interest regimes. It is a searchable database of compliance documents required under the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. The registry contains all the information about individual regulatees that the Commissioner is authorized to make public. The total number of public registry postings increased by more than 200%. Factors included the completion of the initial compliance process by Members and changes to some internal processes that resulted in additional postings. There were 39,296 public registry visits in 2020-2021, up 59% from the previous fiscal year. The Office actively sought to draw attention to the registry in the interests of transparency and public education. For example, it tweeted about compliance matters, such as compliance orders and administrative monetary penalties under the Act and a monthly compliance status report under the Conflict of Interest Code for Members of the House of Commons. In 2020-2021, public office holders declared: 25 agreed compliance measures174 assets39 gifts or other advantages59 liabilities*133 outside activities28 recusals350 summary statements1 instance of travel*8 post-employment exemptions, waivers or reductions12 others *ministers and parliamentary secretaries only​ Direction and advice Public office holders, and especially reporting public office holders, frequently consult the Office for consistent, fair and appropriate advice. While advisors in the Office are the usual point of contact for these consultations, the Commissioner is actively engaged in compliance files and pays special attention to those that may be particularly complex or sensitive. He is always available to speak personally with regulatees about their individual situations. The Office responded to 2,237 requests for advice from public office holders, an increase of 15% from the previous year. It did so within three business days in 90% of cases in 2020-2021, surpassing the targeted 80% mark for this service standard. In 2020-2021, public office holders asked about: gifts or other advantages (5%)outside activities (9%)post-employment obligations (16%)general obligations (25%)material changes (45%)​ Education and outreach In 2020-2021, the Office issued three updated information notices​ that explain how various provisions of the Conflict of Interest Act apply and, where relevant, the Commissioner’s interpretations, to help public office holders understand their obligations. One on the divestment of assets and blind trusts​ and one on the reimbursement of costs​ associated with the divestment of assets and withdrawal of activities were released in June 2020. An information notice on offers of outside employment was released in Feb​ruary 2021. The Office gave nine presentations to offices and organizations with regulatees subject to the Act, and in October 2020 the Commissioner hosted a teleconference on recusals, reaching more than 300 participants. The Office also used Twitter (@EthicsCanada) to let public office holders know about new information that can help them understand and comply with the Act. The Office tweeted 52% more times compared to the previous year. In a January 2021 op-ed published in The Hill Times, the Commissioner reached out to regulatees who might be thinking of changing jobs, reminding them of the Act’s post-employment rules and noting the importance of understanding and complying with them. Enforcement Administrative monetary penalties The Commissioner can impose administrative monetary penalties of up to $500 for failures to meet certain reporting requirements of the Act within established deadlines. In 2020-2021, the Office issued 11 administrative monetary penalties. If the Commissioner believes on reasonable grounds that a public office holder has contravened a reporting requirement of the Act, he may issue a notice of violation in which a proposed penalty is set out. The regulatee has 30 days to pay the penalty or submit written representations. If representations are received, the Commissioner will decide, on a balance of probabilities, whether a violation was committed and whether there were mitigating circumstances. After allowing regulatees some flexibility in meeting their reporting deadlines in the early days of the COVID-19 pandemic, the Commissioner issued 17 notices of violation in 2020-2021.​ When a penalty is issued, the Act requires that the Commissioner make public the nature of the violation, the name of the public office holder and the amount of the penalty. The Office posts penalties in the public registry and, in support of the Commissioner’s commitment to being open and transparent, shares them with a wider audience via Twitter. Compliance orders Under section 30 of the Conflict of Interest Act, the Commissioner may order a public office holder to take any compliance measure the Commissioner determines is necessary to comply with the Act, such as submitting documents for the annual review, ceasing prohibited outside activities or divesting controlled assets. Under section 41 of the Act, if the Commissioner determines that a former reporting public office holder is not complying with their post-employment obligations, the Commissioner may order any current public office holder not to have official dealings with that former reporting public office holder. In September 2020, the Commissioner ordered nine current public office holders, including ministers, ministerial staff members and senior departmental officials, not to have official dealings with former reporting public office holder David MacNaughton for a period of one year. This was the first time a section 41 order was issued. Mr. MacNaughton served as Canada’s Ambassador to the United States. His last day in public office was August 22, 2019, after which he became a former reporting public office holder subject to the Act’s post-employment rules. He became President of Palantir Technologies Canada on September 4, 2019. As a former reporting public office holder, Mr. MacNaughton was required, under section 37 of the Act, to report to the Commissioner any communication referred to in paragraph 5(1)(a) of the Lobbying Act and any meeting referred to in paragraph 5(1)(b) of that Act that he had or arranged in the year following his last day in office. Mr. MacNaughton reported that between March 2 and May 1, 2020, he communicated with or arranged multiple meetings with several public office holders to offer Palantir’s pro bono assistance with the Government of Canada’s response to the COVID-19 pandemic, although no contracts were awarded to Palantir as a result. The Commissioner, having determined that Mr. MacNaughton contravened section 33 of the Act, which prohibits former public office holders from acting in such a manner as to take improper advantage of their previous public office, issued a section 41 order.​ Examinations Under section 44 of the Conflict of Interest Act, the Commissioner can launch an examination of a possible contravention of the Act at the request of a Senator or Member of the House of Commons who provides reasonable grounds to believe the Act has been contravened. The Commissioner also has the discretion under section 45 of the Act to conduct an examination on his own initiative if he has reason to believe that a public office holder or former public office holder has contravened the Act. The Commissioner may decide to do so based on information from various sources, including media reports and complaints from members of the public. In March 2021, the Office created a Request for an Examination form for use by members of the public who wish to submit information about alleged contraventions of the Act. It is supported by a new How to Request an Examination page that also includes information for parliam​entarians. It takes an average of 8 months to complete an examination report. As of March 31, 2021, the Office was working on​ three examinations under the Act. They included two examinations, launched in July 2020, of the conduct of Prime Minister Justin Trudeau and former Finance Minister Bill Morneau in relation to the administration of the Canada Student Service Grant by the WE organization. The Office is often asked for information about examinations that are in progress, but strict confidentiality requirements set out in the Act prevent it from providing any information.​ The Commissioner issues a public report when an examination is completed. When the Commissioner decides to discontinue an examination launched under section 44 of the Act in response to a request from a Senator or Member, a discontinuance report is issued. However, when the Commissioner discontinues an examination that he launched on his own initiative under section 45 of the Act, he is not required to issue a report.​ Examination case files The Office may open a case file when it receives information about a possible contravention of the Act, whether from a Senator or Member of the House of Commons, or through media reports or complaints from members of the public. Some of these initial reviews lead to examinations. Barring exceptional circumstances, the Office’s target is to conduct examinations within a 12-month timeframe. In others, an examination is not found to be warranted and the files are closed. How many case files were opened and closed?​Total case files (a case file is a concern that is reviewed by the Office)​46​Ongoing​​7​Closed without an examination​35​Closed with publication of report4​Who was the subject of each case fi​le?*​​Current or former minister and parliamentary secretary​26​Current or former public office holder​​23​Person not subject to the Act​1​What was the source of these case files?​​Member of the general public​15​Within the Office​12​Member of the House of Commons​9​Media​5​Office of the Public Sector Integrity Commissioner​5​​​What was the nature of the concern?*​Furthering a private interest​23​Duty to recuse​11​Post-employment rules​9​Influence​8​Preferential treatment​7​Private air travel​3​Prohibited activities​3​Public declaration​3​Insider information​2Gifts and other advantages2 *some case files have more than one subject or concern Referrals from the public sector integrity commissioner Matters may be referred to the Commissioner by the Public Sector Integrity Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act. When such a referral is received, the Commissioner is required, under section 68 of the Conflict of Interest Act, to issue a report, which is made public. The report must set out the facts in question, the analysis of the situation and the conclusion, whether or not an examination is launched. In 2020-2021, the Office issued four reports as a result of referrals from the Public Sector Integrity Commissioner. None of those referrals resulted in an examination: In the Qualtrough Report, issued on April 22, 2020, the Commissioner found no reason to believe the Act may have been contravened and decided not to pursue a formal examination. An allegation of conflict of interest had been made against the Honourable Carla Qualtrough, then Minister of Public Services and Procurement Canada, in relation to the appointment of Ms. Moreen Miller as Chairperson of the Board of Directors of Defence Construction Canada. In the Miller Report​, issued on April 22, 2020, the Commissioner found no reason to believe the Act may have been contravened and decided not to pursue a formal examination. Allegations of conflicts of interest had been made against Ms. Moreen Miller, Chairperson of the Board of Directors of Defence Construction Canada. In the Report on alleged wrongdoing by a tribunal member, issued on July 9, 2020, the Commissioner concluded there was no reason to believe the Act may have been contravened and decided not to pursue a formal examination. Allegations of a conflict of interest had been made by two members of a federal administrative tribunal against another member of the same tribunal in relation to the selection of members for an internal training opportunity. In the Report on alleged wrongdoing by a Deputy Minister, issued on September 30, 2020, the Commissioner concluded there was no reason to believe the Act may have been contravened and decided not to pursue a formal examination. Two allegations had been made by some federal department employees against their deputy minister. The first was that the deputy minister interfered in the hiring process for a senior level position in their department to benefit a friend. The second was that they intervened in an internal investigation conducted under the Public Servants Disclosure Protection Act. The Commissioner found that the second allegation was outside of his mandate so did not consider it further. Regarding the first allegation, he had no reason to believe that the deputy minister may have contravened the Act. Public communications The volume of communications from the media and members of the public was slightly lower in the spring of 2020. It rose significantly in mid-summer when Parliament began studying the administration of the Canada Student Service Grant by the WE organization and the Commissioner launched two related examinations under the Conflict of Interest Act. The following chart tracks how some of the Office’s key public communications in 2020-2021 compared to the previous year. Website The Office continues to make a range of information available on its website to help educate and inform regulatees, the media and the public. There were 32% fewer website visitors. (44,279 website visitors) Social media In 2020-2021, the Office changed its Twitter handle to @EthicsCanada. It further increased its tweet activity and expanded the range of subjects it tweets about to include, for example, compliance orders and job postings. The number of followers grew by 148%, further increasing the Office's social media reach. The Office tweeted 52% more times. (3,093 followers and 260 tweets) Media and public inquiries The Office provides as much information as it is can when responding to information requests from the media and members of the public. The Commissioner also participated in 9 interviews with journalists in 2020-2021. The Office strives to respond in a timely manner and has established service standards to do so. The target for achieving those standards was set at 80%. Media requests were responded to within four hours in 88% of cases. Communications from the public were responded to within two weeks in 82% of cases. The Office received 27% more public inquiries. (177 media inquiries and 2,043 public inquiries) Presentations The Commissioner and representatives of the Office give a variety of presentations to help Canadian and international audiences understand the Commissioner's role and mandate. They include academic institutions and ethics organizations based in Canada and other countries. In 2020-2021, the Commissioner was invited by the United Kingdom's independent Committee on Standards in Public Life to appear before it to discuss the workings of Canada's federal ethics regimes. He also participated in a panel discussion organized by members of the European Parliament to discuss the importance of the role of ethics and transparency in public governance structures. The Office gave 60% fewer presentations to the general public. Because of the COVID-19 pandemic, it received fewer requests for presentations and did not proactively offer as many. (10 presentations and 437 participants) Collaboration and best practices Public health restrictions imposed by the COVID-19 pandemic prompted a shift from in-person to online interactions throughout the year. Thanks to the technology that makes it possible to have productive and effective meetings virtually, the Office continued to maintain and strengthen connections with officials and organizations in Canada and other countries.​ Mario Dion, Conflict of Interest and Ethics Commissioner Domestic outreach The Commissioner participated in the annual meeting of the Canadian Conflict of Interest Network (CCOIN) in September 2020 and in its semi-annual meeting in March 2021. The Commissioner continued to liaise occasionally with other agents of Parliament and Office employees did the same with their counterparts in those agents’ offices. In 2020-2021, the Commissioner spoke about his role and mandate with classes at several Canadian universities: Carleton, Dalhousie, Ottawa, Queen’s, Thompson Rivers and York. International outreach In 2020-2021, the Office remained active in the Réseau francophone d’éthique et de déontologie parlementaires (RFEDP​) [link in French only] within the Organisation internationale de la Francophonie. In November 2020, the Commissioner and several members of the Office participated in the RFEDP’s first annual general meeting. The Office is now involved in two RFEDP working groups, one focussed on training and the other on best practices. In November 2020, a senior Office representative participated in a meeting of the Organisation for Economic Co-operation and Development (OECD)’s Working Party of Senior Public Integrity Officials (SPIO). In December 2020, a senior Office representative attended the annual conference of the Council on Governmental Ethics Laws (COGEL), a U.S.-based international not-for-profit organization of government ethics practitioners. The Office is a member and other Canadian conflict of interest and integrity offices are also active in it. In March 2021, Office representatives attended in the OECD’s Global Anti-Corruption and Integrity Forum. At the invitation of the Committee, the Commissioner appeared before the United Kingdom’s independent Committee on Standards in Public Life (CSPL) in March 2021 to discuss​ how Canada’s federal ethics regimes work and to note the similarities and differences between Canada’s regime and the Seven Principles of Public Life (also known as the Nolan Principles) that underpin the U.K. rules. The Commissioner was asked about his role in building public trust and informing public debate on ethical standards.​ The Commissioner, together with the Office’s Director of Communications, Outreach and Planning, participated in a March 2021 panel discussion organized by members of the European Parliament. Canada’s Lobbying Commissioner and the Secretary General for the French High Authority for Transparency in Public Life also participated in this open conversation about democratic systems that support transparency and the integrity of public officials in their respective countries. The Office provided input for international surveys and peer reviews about the United Nations Convention against Corruption (UNCAC), the Mechanism for Follow-Up on the Implementation of the Inter-American Convention against Corruption (MESICIC) of the Organization of American States (OAS​), and a G-20 questionnaire on corruption measurement. It also reviewed a document for the OECD’s Working Party of Senior Public Integrity Officials: a draft report on progress made by the OECD and selected countries in implementing the OECD’s 2010 recommendation on Principles for Transparency and Integrity in Lobbying. Contacts with Parliament​ The Conflict of Interest and Ethics Commissioner is an independent officer of the House of Commons who reports directly to Parliament, through the Speaker of the House of Commons, on behalf of Canadians. The Commissioner is required to submit an annual report on the administration of the Conflict of Interest Act to Parliament by June 30 for tabling with the Speakers of the Senate and the House of Commons. He reports on examinations under the Act to the Prime Minister. The Office sends communiqués to parliamentarians when reports are tabled or released. Eight communiqués were sent in 2020-2021. The Commissioner also testifies before parliamentary committees about the Office and its work. He did so virtually this year because of the COVID-19 public health restrictions. On November 24, 2020, the Commissioner appeared before the House of Commons Standing Committee on Finance, in the context of its study on government spending, the WE organization and the Canada Student Service Grant. On November 27, 2020, the Commissioner appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics on questions of conflict of interest and lobbying in relation to pandemic spending. Our tools The Office’s accomplishments result from the hard work, dedication and resilience of its employees in implementing the Commissioner’s vision, with the support of a sound internal management framework. Our people To ensure the Office has the human resources it needs to fulfill its vision and achieve its mission, 13 staffing processes were completed or initiated in 2020-2021. To increase the reach of its job postings, in November 2020 it started announcing employment opportunities on Twitter. The Office expanded purchasing to provide all employees with equipment at home to support their physical work requirements in the telework environment. It spent $28,000, an average of $560 per employee, on equipment such as desks, chairs and computer monitors, to support telework. Those costs were more than offset by pandemic-related savings totalling $45,000 on travel, printing and postage, for net savings of $17,000. It also made resources available to help them deal with any possible negative effects on their mental health of the COVID-19 pandemic and the transition to telework. This and other initiatives were supported by the Office’s Quality Workplace Promotion Committee.​ A comprehensive plan was developed to strengthen and expand internal communications, whose importance has only grown in the telework environment. Commissioner's Office 4 positions Advisory and Compliance 20 positions Investigations and Legal Services 8 positions Communications, Outreach and Planning 8 positions Corporate Management 11 positions Our infrastructure The Office continued to update its suite of policies and guidelines in line with those of other parliamentary entities and the wider public service. To make internal operations more efficient, the Office implemented a new document management system and a new human resources management system. The Office’s financial statements are audited each year by an independent external auditor. The Financial Resources Summary appended to this report outlines its financial information for the 2020-2021 fiscal year. Our plan Upholding a strong culture of integrity in government decision making is essential to safeguard the public interest and strengthen public trust and confidence in democracy. A culture of integrity aims to foster an environment in which everyone is encouraged to actively identify and avoid conflicts of interest by taking the appropriate mechanisms to address them and to solve ethical dilemmas. The Office contributes to the achievement of this goal by administering key components of Canada’s federal conflict of interest prevention and management system. In 2020-2021, the Office developed a new three-year strategic plan with a view to reinforcing and expanding the culture of integrity that it seeks to foster while continuing to move forward with core projects. The plan identifies specific outcomes and priorities that will help guide projects and activities in support of the Office’s mission. The following key focus areas were established for 2021-2024, to be supported by identified projects, activities and performance indicators. Stakeholder communications and engagementPeople and cultureInformation managementInformation technologyApproach to compliance assurance The strategic plan is an evergreen tool that is meant to capture the Commissioner’s vision. Our challenges External developments can impact the way the Office implements its mandate. The Commissioner believes challenges are opportunities that carry the potential for positive change. Adapting to pandemic imperatives As a result of public health restrictions introduced in response to the COVID-19 pandemic in spring 2020, the Commissioner suspended in-office operations and directed employees to telework. While some employees worked on-site from time to time as necessary, the work-from-home model remained in effect for the Office as a whole throughout the 2020-2021 fiscal year. At the same time, the House of Commons and its committees adopted a hybrid remote/in-person approach to meeting and conducting parliamentary business. No major issues were encountered, and the Office was able to successfully meet its mandate, while maintaining confidentiality at all times. While the Office dealt with its workload, it continued to meet its established service standards. The Office adopted new tools to support employees and the needs of regulatees, reordered some priorities to meet evolving circumstances and, in the early days of the pandemic, allowed regulatees some flexibility in meeting compliance deadlines. It also adapted the investigations process. It was important to ensure the Office could continue to conduct investigations with due dispatch while still executing them thoroughly, with proper diligence and respect for procedural fairness. This meant, for example, being able to conduct interviews remotely and securely, receive and review documentary evidence and maintain the confidentiality of the investigative process. The Office’s investigation adaptations were put to the test with the launch of two high-profile, resource-intensive examinations under the Act. In July 2020, in response to examination requests submitted by parliamentarians, the Commissioner started investigating the conduct of Prime Minister Justin Trudeau and that of former Finance Minister Bill Morneau in relation to the administration of the Canada Student Service Grant by the WE organization. Adding to the challenge was the exceptionally large scope of work that these examinations entailed. As the Commissioner noted during his appearance before the Standing Committee on Finance on November 24, 2020, the Office had received tens of thousands of pages of documentary evidence. When testifying before the Standing Committee on Access to Information, Privacy and Ethics on November 27, 2020, he discussed the approach to reviewing documents and witness testimony. The modified working conditions under which the Office and others were operating also had other positive results for the Office that had not been anticipated. Office representatives were able to participate remotely in events and presentations in Canada and around the world, conveniently and at low cost, which they might otherwise not have attended in person. For example, in March 2021, the Commissioner participated in a discussion with members of the European Parliament and testified before the United Kingdom’s independent Committee on Standards in Public Life. Participating in both events, which took place on the same day, would have been logistically impossible had they been held in-person. Videoconferencing technology also enabled the Commissioner to meet with university classes in several Canadian provinces. The Office also went fully paperless in its communications with regulatees, building on earlier moves to expand its use of electronic communications. Court matters Matters involving the Office have been the object of several applications for judicial review. While dealing with them can consume a significant amount of resources, they can also be opportunities to clarify the Commissioner’s mandate and powers. Only one court matter is outstanding as of March 31, 2021: Democracy Watch v. Canada (Attorney General) (A-331-19): Democracy Watch filed an application for judicial review challenging the Commissioner’s findings in the Trudeau II Report. The applicant seeks to quash the findings of the report on the basis that the Commissioner erred in law, failed to exercise his jurisdiction and failed to observe a principle of natural justice by not acknowledging a request for examination received by Ms. Elizabeth May, Member of Parliament for Saanich–Gulf Islands. The applicant further argues that the Commissioner, who was appointed by the Governor in Council, failed to exercise his jurisdiction and exhibited a reasonable apprehension of bias in his decision not to examine the conduct of other public office holders involved in the matter. A hearing date has not been set. Appendix Financial resources summary​ ​(thousands of dollars) ​​Program Activity ​2019-2020 Actual Spending 2020-2021 ​Alignment toGovernment of CanadaOutcomes​ ​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 ​ 6,199 ​ 6,715 ​ 6,715 ​ 6,305 Government AffairsContributions to employee benefit plans687800800756 Total spending6,8867,5157,5157,061 Plus: cost of services received without charge1,134n/an/a1,127 Net cost of department 8,0207,5157,5158,188 The budget process for the Office of the C​onflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on our Office’s effectiveness, management and operations, together with its operational and expenditure plans. The figures in this summary have not been audited. Complete audited financial statements will be available on our website.

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 my 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, 2021, 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, Mario DionConflict of Interest and Ethics Commissioner​ 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 2020-2021. In response to the changes brought by the COVID-19 pandemic, we fully adapted our processes to telework and moved to electronic paperless communications with regulatees. Modifications to our processes and technology, coupled with the diligence and hard work of employees, enabled the Office to successfully manage a high volume of work across all activity areas in support of its vision and mission. We ended the fiscal year with no significant backlogs of work anywhere in the organization. We worked with Members to finalize their initial compliance process under the Code following the October 2019 election. All Members elected or re-elected at that time completed the process by October 2020. We also provided direction and advice in almost 500 instances to help them meet their obligations. After receiving several requests for advice from Members about federal COVID-19 emergency relief programs, in April 2020 I published an advisory opinion so that all Members could benefit from clear and consistent direction in support of the purposes and principles of the Code. The advisory opinion clarified that Members may benefit from such programs for which they are eligible and support constituents seeking assistance from those programs. We supported transparency by maintaining the public registry, publishing quarterly statistical reports on our activities and issuing a monthly Members’ Compliance Status Report and the 2020 List of Sponsored Travel. We released one inquiry report, in which I found that a Member failed to meet his initial compliance obligations under the Code. The report marked the first time that a federal Conflict of Interest and Ethics Commissioner has recommended a sanction in an inquiry report. We were active in the area of education and public communications. We expanded our social media presence and changed our Twitter handle to @EthicsCanada. We also engaged with our counterparts in Canada and around the world on various initiatives. We began preparations for the House of Commons Standing Committee on Procedure and House Affairs’ five-year review of the Code that was anticipated in 2020. Building on the work accomplished by the Office in the past three years, we developed a new three-year strategic plan to help guide our activities going forward. I remain honoured to serve Parliament and Canadians and am grateful to the employees of the Office for helping me fulfill my mandate.​ Our vision Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament. Our mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.​ Our stakeholders The Office’s stakeholders include regulatees—the individuals subject to the conflict of interest regimes it administers—as well as Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report touches on all stakeholder groups, but its focus is the Members of the House of Commons who are subject to the Conflict of Interest Code for Members of the House of Commons. Members are key stakeholders of the Office. One of its strategic objectives is to increase trust in and credibility of the Office with key stakeholders so that they become stronger allies in the delivery of its mandate and can effectively manage conflict of interest issues. The Commissioner is also mandated under section 32 of the Code to undertake educational activities for Members regarding the Code and the role of the Commissioner. The Office’s quarterly statistical reports provide an accurate reflection of the fluctuations that occur throughout the year. The following graph provides a snapshot of Members on March 31, 2021.​ On March 31, 2021, there were 338 elected Members of the House of Commons of which: 11% were ministers11% were parliamentary secretaries78% were Members of the House of Commons who are not ministers or parliamentary secretaries Ministers and parliamentary secretaries are also subject to the Conflict of Interest Act. Our achievements​ Key activities​ Compliance​Helping regulatees achieve and maintain compliance with the conflict of interest regimes​Direction and advice​​Giving regulatees confidential guidance tailored to their individual situations​Education and outreach​Helping regulatees understand their obligations under the regimes​Enforcement​​Applying investigation and other enforcement provisions of the regimes as appropriate​​Public communications​Educating and informing regulatees, the media and the general public​​Collaboration and best practices​​Exchanging information with domestic and international counterparts​​Contacts with Parliament​Reporting to Parliament and testifying before its committees​ Compliance In support of its mission to ensure full compliance with the conflict of interest regimes that it administers, the Office devotes most of its resources to helping regulatees achieve and maintain compliance with those regimes. Reflecting one of its strategic objectives, the Office is developing a more preventive approach to compliance assurance that provides proactive guidance to regulatees, including direction on ethical issues. Employees in the Advisory and Compliance division guide Members through the compliance processes under the Conflict of Interest Code for Members of the House of Commons, give them confidential advice supported by legal opinions on individual files as necessary, post their publicly declarable information in the public registry and ensure they have the information they need to understand their obligations. The Office’s contact with Members starts shortly after their election or re-election and continues throughout their time in office. The Office helps Members comply with the Code: by contacting them as soon as they are elected(2 communications)by ensuring they complete their initial compliance process(270 processes)by giving them advice when they need it (490 instances)by contacting them annually (61 reviews)by posting their information in the public registry (519 reviews)​ Initial compliance process All Members must complete an initial compliance process under the Code. Indeed, helping Members complete this important process was a main focus for the Office in the past year. The initial compliance process begins soon after Members are elected or re-elected in a general election or by-election, when their name is published in the Canada Gazette. Employees in the Advisory and Compliance division guide them through it every step of the way. The Commissioner is kept abreast of all Members’ files throughout. The Office communicates with Members in their preferred official language, as indicated by Elections Canada. Members may also inform the Office whether they wish to communicate in English or French. All Members elected or re-elected in October 2019 completed the initial compliance process under the Code by October 2020. The two Members elected in the October 2020 by-elections completed it before the end of March 2021.​ Initial compliance process for Members of the House of Commons Office sends first letter within three days of publication in the Canada Gazette (with copy of Code and other supporting documents) 2 first letters sent to new Members elected in October 2020 by-electionsMember files confidential Disclosure Statement, no later than 60 days after notice of their election or re-election appears in the Canada Gazette Member participates in initial compliance call with advisor from Office 123 initial compliance calls madeOffice sends intermediate letter with Disclosure Summary 208 intermediate letters sentMember signs and returns Disclosure Summary, within 60 days Office sends final letter, signalling end of initial compliance process 270 final letters sent The Office maintains a Members’ Compliance Status Report that identifies where each Member is in the initial compliance process. It was previously produced on an as-needed basis and more frequently after general elections. Starting in January 2020, and with a hiatus at the start of the COVID-19 pandemic, an updated status report was published monthly until all Members had completed the initial compliance process. The report will remain static until the next election or by-election. As of March 31, 2021, all Members had completed the initial compliance process. Ongoing reporting requirements After completing the initial compliance process, Members must meet various reporting requirements throughout their time in office.​ Ongoing reporting requirements Annual review 61 annual reviews initiated and 26 receivedMaterial changes Gifts and other benefits 123 initial compliance calls madeSponsored travel Sponsored travel totalled $27,739 in calendar year 2020Private interests Public registry The public registry supports transparency, a pillar of effective conflict of interest regimes. It is a searchable database of compliance documents required under the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. The registry contains all the information about individual regulatees that the Commissioner is authorized to make public. The total number of public registry postings increased by more than 200%. Factors included the completion of the initial compliance process by Members and changes to some internal processes that resulted in additional postings. There were 39,296 public registry visits in 2020-2021, up 59% from the previous fiscal year. The Office actively sought to draw attention to the registry in the interests of transparency and public education. For example, it tweeted about compliance matters, such as a monthly compliance status report under the Code and compliance orders and administrative monetary penalties under the Conflict of Interest Act. In 2020-2021, Members declared the following: 371 disclosure summaries119 material changes7 instances of sponsored travel (calendar year)42 gifts or other benefits​1 private interest Direction and advice Members frequently consult the Office for consistent, impartial, fair and appropriate advice. While advisors in the Office are the usual point of contact for these consultations, the Commissioner is actively engaged in compliance files and pays special attention to those that may be particularly complex or sensitive. He is always available to speak personally with Members about their individual situations. The Office responded to 490 requests for advice from Members within three business days in 90% of cases in 2020-2021, surpassing the targeted 80% mark for this service standard. In 2020-2021, Members asked about: letters of support and fundraising: (9%)gifts or other advantages (16%)material changes (31%)​general obligations (44%)​ Following the announcement of federal programs to support Canadians and businesses facing financial hardship because of the COVID-19 pandemic, the Office received several requests for advice from Members about whether they could benefit from those programs or help their constituents do so. In April 2020, the Commissioner published an advis​ory opinion under subsect​ion 26(4) of the Code so that all Members could benefit from clear and consistent direction in support of the purposes and principles of the Code. The advisory opinion clarified that Members may benefit from COVID-19 emergency relief programs for which they are eligible. For example, Members involved in outside activities such as carrying on a business, being a partner in a partnership, or engaging in employment or in the practice of a profession may be affected by economic repercussions relating to COVID-19. It also clarified that Members may support constituents seeking assistance from those programs. Because the matter in question may directly or indirectly affect the interests of Members or those of the members of their families, as well as those of their constituents as members of a broad class of the public, Members would not be prohibited under the Code from using their parliamentary duties and functions to further these interests. Education and outreach The Commissioner has a specific mandate under section 32 of the Conflict of Interest Code for Members of the House of Commons to undertake educational activities for Members and the general public regarding the Code and the role of the Commissioner. In December 2020, the Commissioner participated in two presentations, one in each official language, organized by the Library of Parliament for Members of the House of Commons and their staff, reaching a total of 54 participants. The Office has used Twitter (@EthicsCanada) to let Members know about new information that can help them understand and comply with the Code. It sent 260 tweets about its activities, role and mandate in 2020-2021, an increase of 52% from the previous year. It also responded to 2,043 requests from members of the public for information about its work. The Office makes information about the Code’s requirements available on its website.​ Enforcement The Commissioner can conduct inquiries of possible contraventions of the Conflict of Interest Code for Members of the House of Commons and the inquiry reports are made public. Any Member who has reasonable grounds to believe that another Member has contravened the Code may ask the Commissioner to investigate by submitting a signed, written request that identifies the alleged non-compliance and sets out reasonable grounds for the belief that the Code has been contravened. The average time to complete an inquiry is just over 5 months. When the Office receives a valid request for an inquiry, it must forward it without delay to the Member named in the request and give them 30 days to respond. After receiving their response, the Commissioner conducts a preliminary review to determine if an inquiry is warranted. Within 15 working days of receiving the response, the originator of the request and the Member named in it are notified of the Commissioner’s decision as to whether or not an inquiry will be conducted. Under paragraph 27(5.1)(iii) of the Code, the reasons for not proceeding with an inquiry may be described if the matter to which the inquiry relates has already been made public. The House of Commons may also direct the Commissioner, by way of resolution, to conduct an inquiry, although this has not yet occurred since the Cod​e was adopted in 2004. The Commissioner also has the discretion to conduct an inquiry on his own initiative. Barring exceptional circumstances, the Office’s target is to conduct inquiries within a 12-month timeframe. Sanctions​ ​The Commissioner is not empowered to impose sanctions under the Code but may recommend sanctions in inquiry reports. Section 28 of the Code provides that, following an inquiry in which the Commissioner concludes, for example, that a Member has not complied with an obligation under the Code and did not take all reasonable measures to prevent the non-compliance, or where a request for an inquiry was frivolous, vexatious or was not made in good faith, the Commissioner may recommend that the House of Commons impose appropriate sanctions. Only the House of Commons has the right to discipline its own Members and is responsible for imposing and administering sanctions, including any that may be recommended by the Commissioner. The Commissioner recommended a sanction in the Maloney Report (see Inquiries section below), the first time a Federal Conflict of Interest and Ethics Commissioner recommended a sanction in an inquiry report. In the Peschisolido Report, the Commissioner had declined to recommend a sanction even though he found that Mr. Joe Peschisolido had contravened the Code’s disclosure obligations. The Commissioner stated that, as Mr. Peschisolido was no longer a Member and therefore no longer subject to the Code, recommending a sanction would serve no purpose. However, Mr. Peschisolido sent a communication to the House of Commons, which the Speaker tabled in the House in October 2020. In it, he apologized to the House for his late reporting under the Code.​ Inquiry case files When the Office receives information about a possible contravention of the Code, including through media reports or complaints from members of the public, a case file is opened. The information is reviewed to determine whether the concern raised falls within its mandate and, if it does, whether there is reason to believe that a contravention of the Code has occurred. Some of these initial reviews lead to inquiries. In other cases, an inquiry is not found to be warranted and the files are closed. Inquiry case files in 2020-2021 How many case files were opened and closed?​​Total case files (a case file is a concern that is reviewed by the Office)​21​Ongoing​​5​Closed without an inquiry​15​Closed with publication of report​​1Who was the subject of each case file?​Current or former Member of the House of Commons20​Person not subject to the Code​​1​What was the source of these case files?​​Member of the House of Commons​8​Within the Office​7​Member of the general public6​​​What was the nature of the concern?*​Preferential treatment9​Making decisions, or seeking to influence decisions, that would further a private interest6​Disclosure of information​5Attempt to engage in prohibited activities2​ *some case files have more than one concern Inquiries In 2020-2021, the Office issued one inquiry report under the Conflict of Interest Code for Members of the House of Commons: In the Maloney Report, issued on November 19, 2020, the Commissioner found that Mr. James Maloney, Member of Parliament for Etobicoke–Lakeshore, contravened paragraph 20(1)(i) of the Code by failing to file a complete Disclosure Statement within a reasonable time after his extended deadline for doing so had passed. He further found that no mitigating circumstances applied given the length of the delay. Having considered Mr. Maloney’s disregard for his post-election obligations under the Code, the Commissioner recommended that the House of Commons require Mr. Maloney to apologize to it for having failed to fulfill his obligations as a Member in the context of his initial compliance process under the Code. Mr. Maloney apologized to the House on November 19, 2020, the same day the report was tabled. As of March 31, 2021, one inquiry, into the conduct of Ms. Yasmin Ratansi, Member of Parliament for Don Valley East, was ongoing. The Office confirmed in March 2021 that the Commissioner had commenced an inquiry, but is prevented by subsection 27(5.1), which limits public comments on inquiries, from providing any details.​ Public communications ​The volume of communications from the media and members of the public was slightly lower in the spring of 2020. It rose significantly in mid-summer when Parliament began studying the administration of the Canada Student Service Grant by the WE organization and the Commissioner launched two related examinations under the Conflict of Interest Act. The following chart tracks how some of the Office’s key public communications in 2020-2021 compared to the previous year.​ ​Website The Office continues to make a range of information available on its website to help educate and inform regulatees, the media and the public. There were 32% fewer website visitors. (44,279 website visitors) Social media In 2020-2021, the Office changed its Twitter handle to @EthicsCanada. It further increased its tweet activity and expanded the range of subjects it tweets about to include, for example, compliance orders and job postings. The number of followers grew by 148%, further increasing the Office's social media reach. The Office tweeted 52% more times. (3,093 followers and 260 tweets) Media and public inquiries The Office provides as much information as it is can when responding to information requests from the media and members of the public. The Commissioner also participated in 9 interviews with journalists in 2020-2021. The Office strives to respond in a timely manner and has established service standards to do so. The target for achieving those standards was set at 80%. Media requests were responded to within four hours in 88% of cases. Communications from the public were responded to within two weeks in 82% of cases. The Office received 27% more public inquiries. (177 media inquiries and 2,043 public inquiries) Presentations The Commissioner and representatives of the Office give a variety of presentations to help Canadian and international audiences understand the Commissioner's role and mandate. They include academic institutions and ethics organizations based in Canada and other countries. In 2020-2021, the Commissioner was invited by the United Kingdom's independent Committee on Standards in Public Life to appear before it to discuss the workings of Canada's federal ethics regimes. He also participated in a panel discussion organized by members of the European Parliament to discuss the importance of the role of ethics and transparency in public governance structures. The Office gave 60% fewer presentations to the general public. Because of the COVID-19 pandemic, it received fewer requests for presentations and did not proactively offer as many. (10 presentations and 437 participants)​ Collaboration and best practices Public health restrictions imposed by the COVID-19 pandemic prompted a shift from in-person to online interactions throughout the year. Thanks to the technology that makes it possible to have productive and effective meetings virtually, the Office continued to maintain and strengthen connections with officials and organizations in Canada and other countries. Mario Dion, Conflict of Interest and Ethics Commissioner Domestic outreach The Commissioner participated in the annual meeting of the Canadian Conflict of Interest Network (CCOIN) in September 2020 and in its semi-annual meeting in March 2021. The Commissioner continued to liaise occasionally with other agents of Parliament and Office employees did the same with their counterparts in those agents’ offices. In 2020-2021, the Commissioner spoke about his role and mandate with classes at several Canadian universities: Carleton, Dalhousie, Ottawa, Queen’s, Thompson Rivers and York. International outreach In 2020-2021, the Office remained active in the Réseau francophone d’éthique et de déontologie parlementaires (RFEDP​) [link in French only] within the Organisation internationale de la Francophonie. In November 2020, the Commissioner and several members of the Office participated in the RFEDP’s first annual general meeting. The Office is now involved in two RFEDP working groups, one focussed on training and the other on best practices. In November 2020, a senior Office representative participated in a meeting of the Organisation for Economic Co-operation and Development (OECD)’s Working Party of Senior Public Integrity Officials (SPIO). In December 2020, a senior Office representative attended the annual conference of the Council on Governmental Ethics Laws (COGEL), a U.S.-based international not-for-profit organization of government ethics practitioners. The Office is a member and other Canadian conflict of interest and integrity offices are also active in it. In March 2021, Office representatives attended in the OECD’s Global Anti-Corruption and Integrity Forum. At the invitation of the Committee, the Commissioner appeared before the United Kingdom’s independent Committee on Standards in Public Life (CSPL) in March 2021 to discuss​ how Canada’s federal ethics regimes work and to note the similarities and differences between Canada’s regime and the Seven Principles of Public Life (also known as the Nolan Principles) that underpin the U.K. rules. The Commissioner was asked about his role in building public trust and informing public debate on ethical standards.​ The Commissioner, together with the Office’s Director of Communications, Outreach and Planning, participated in a March 2021 panel discussion organized by members of the European Parliament. Canada’s Lobbying Commissioner and the Secretary General for the French High Authority for Transparency in Public Life also participated in this open conversation about democratic systems that support transparency and the integrity of public officials in their respective countries. The Office provided input for international surveys and peer reviews about the United Nations Convention against Corruption (UNCAC), the Mechanism for Follow-Up on the Implementation of the Inter-American Convention against Corruption (MESICIC) of the Organization of American States (OAS​), and a G-20 questionnaire on corruption measurement. It also reviewed a document for the OECD’s Working Party of Senior Public Integrity Officials: a draft report on progress made by the OECD and selected countries in implementing the OECD’s 2010 recommendation on Principles for Transparency and Integrity in Lobbying. Contacts with Parliament The Conflict of Interest and Ethics Commissioner is an independent officer of the House of Commons who reports directly to Parliament, through the Speaker of the House of Commons, on behalf of Canadians. The Commissioner is required to submit an annual report on the administration of the Conflict of Interest Act to Parliament by June 30 for tabling with the Speakers of the Senate and the House of Commons. He reports on examinations under the Act to the Prime Minister. The Office sends communiqués to parliamentarians when reports are tabled or released. Eight communiqués were sent in 2020-2021. The Commissioner also testifies before parliamentary committees about the Office and its work. He did so virtually this year because of the COVID-19 public health restrictions. On November 24, 2020, the Commissioner appeared before the House of Commons Standing Committee on Finance, in the context of its study on government spending, the WE organization and the Canada Student Service Grant. On November 27, 2020, the Commissioner appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics on questions of conflict of interest and lobbying in relation to pandemic spending. Our tools The Office’s accomplishments result from the hard work, dedication and resilience of its employees in implementing the Commissioner’s vision, with the support of a sound internal management framework. Our people To ensure the Office has the human resources it needs to fulfill its vision and achieve its mission, 13 staffing processes were completed or initiated in 2020-2021. To increase the reach of its job postings, in November 2020 it started announcing employment opportunities on Twitter. The Office expanded purchasing to provide all employees with equipment at home to support their physical work requirements in the telework environment. It spent $28,000, an average of $560 per employee, on equipment such as desks, chairs and computer monitors, to support telework. Those costs were more than offset by pandemic-related savings totalling $45,000 on travel, printing and postage, for net savings of $17,000. It also made resources available to help them deal with any possible negative effects on their mental health of the COVID-19 pandemic and the transition to telework. This and other initiatives were supported by the Office’s Quality Workplace Promotion Committee. A comprehensive plan was developed to strengthen and expand internal communications, whose importance has only grown in the telework environment.​ Commissioner's Office 4 employees Advisory and Compliance 20 employees Investigations and legal services 8 employees Communications, Outreach and Planning 8 employees Corporate Management 11 employees Our infrastructure The Office continued to update its suite of policies and guidelines in line with those of other parliamentary entities and the wider public service. To make internal operations more efficient, the Office implemented a new document management system and a new human resources management system. The Office’s financial statements are audited each year by an independent external auditor. The Financial Resources Summary appended to this report outlines its financial information for the 2020-2021 fiscal year. Our plan Upholding a strong culture of integrity in government decision making is essential to safeguard the public interest and strengthen public trust and confidence in democracy. A culture of integrity aims to foster an environment in which everyone is encouraged to actively identify and avoid conflicts of interest by taking the appropriate mechanisms to address them and to solve ethical dilemmas. The Office contributes to the achievement of this goal by administering key components of Canada’s federal conflict of interest prevention and management system. In 2020-2021, the Office developed a new three-year strategic plan with a view to reinforcing and expanding the culture of integrity that it seeks to foster while continuing to move forward with core projects. The plan identifies specific outcomes and priorities that will help guide projects and activities in support of the Office’s mission. The following key focus areas were established for 2021-2024, to be supported by identified projects, activities and performance indicators. Stakeholder communications and engagementPeople and cultureInformation managementInformation technologyApproach to compliance assurance The strategic plan is an evergreen tool that is meant to capture the Commissioner’s vision.​ Our challenges External developments can impact the way the Office implements its mandate. The Commissioner believes challenges are opportunities that carry the potential for positive change. Adapting to pandemic imperatives As a result of public health restrictions introduced in response to the COVID-19 pandemic in spring 2020, the Commissioner suspended in-office operations and directed employees to telework. While some employees worked on-site from time to time as necessary, the work-from-home model remained in effect for the Office as a whole throughout the 2020-2021 fiscal year. At the same time, the House of Commons and its committees adopted a hybrid remote/in-person approach to meeting and conducting parliamentary business. No major issues were encountered, and the Office was able to successfully meet its mandate, while maintaining confidentiality at all times. While the Office dealt with its workload, it continued to meet its established service standards. The Office adopted new tools to support employees and the needs of regulatees, reordered some priorities to meet evolving circumstances and, in the early days of the pandemic, allowed regulatees some flexibility in meeting compliance deadlines. It also adapted the investigations process. It was important to ensure the Office could continue to conduct investigations with due dispatch while still executing them thoroughly, with proper diligence and respect for procedural fairness. This meant, for example, being able to conduct interviews remotely and securely, receive and review documentary evidence and maintain the confidentiality of the investigative process. The Office’s investigation adaptations were put to the test with the launch of two high-profile, resource-intensive examinations under the Conflict of Interest Act. In July 2020, in response to examination requests submitted by parliamentarians, the Commissioner started investigating the conduct of Prime Minister Justin Trudeau and that of former Finance Minister Bill Morneau in relation to the administration of the Canada Student Service Grant by the WE organization. Adding to the challenge was the exceptionally large scope of work that these examinations entailed. As the Commissioner noted during his appearance before the Standing Committee on Finance on November 24, 2020, the Office had received tens of thousands of pages of documentary evidence. When testifying before the Standing Committee on Access to Information, Privacy and Ethics on November 27, 2020, he discussed the approach to reviewing documents and witness testimony. The modified working conditions under which the Office and others were operating also had other positive results for the Office that had not been anticipated. Office representatives were able to participate remotely in events and presentations in Canada and around the world, conveniently and at low cost, which they might otherwise not have attended in person. For example, in March 2021, the Commissioner participated in a discussion with members of the European Parliament and testified before the United Kingdom’s independent Committee on Standards in Public Life. Participating in both events, which took place on the same day, would have been logistically impossible had they been held in-person. Videoconferencing technology also enabled the Commissioner to meet with university classes in several Canadian provinces. The Office also went fully paperless in its communications with regulatees, building on earlier moves to expand its use of electronic communications. Court matters Matters involving the Office have been the object of several applications for judicial review. While dealing with them can consume a significant amount of resources, they can also be opportunities to clarify the Commissioner’s mandate and powers. Only one court matter is outstanding as of March 31, 2021: Democracy Watch v. Canada (Attorney General) (A-331-19): Democracy Watch filed an application for judicial review challenging the Commissioner’s findings in the Trudeau II Report. The applicant seeks to quash the findings of the report on the basis that the Commissioner erred in law, failed to exercise his jurisdiction and failed to observe a principle of natural justice by not acknowledging a request for examination received by Ms. Elizabeth May, Member of Parliament for Saanich–Gulf Islands. The applicant further argues that the Commissioner, who was appointed by the Governor in Council, failed to exercise his jurisdiction and exhibited a reasonable apprehension of bias in his decision not to examine the conduct of other public office holders involved in the matter. A hearing date has not been set. Appendix Financial resources summary ​​​​ ​​(thousands of dollars)​​​​​Program Activity​​ ​2019-2020 Actual Spending 2020-2021 ​Alignment toGovernment of CanadaOutcomes​ ​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​​ ​ 6,199 ​ 6,715 ​ 6,715 ​ 6,305 ​Government Affairs​Contributi​ons to employee benefit plans​687800800​756​​Total spending​​6,886​​7,515​7,515​7,061​​​​​​​​Plus: cost of services received without charge​1,134​n/a​n/a​1,127​ ​Net cost of department​​​ ​8,020​7,515​7,515​8,188​​​​​​ The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on our Office’s effectiveness, management and operations, together with its operational and expenditure plans. The figures in this summary have not been audited. Complete audited financial statements will be available on our 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 Mr. Speaker: I am pleased to submit to you my 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, 2020, for tabling in the Senate. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Mario DionConflict of Interest and Ethics Commissioner Dear Mr. Speaker: I am pleased to submit to you my 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, 2020, 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, Mario DionConflict of Interest and Ethics Commissioner Commissioner's message I am pleased to report on the administration of the Conflict of Interest Act (Act) in 2019-2020. It was an eventful and productive year. The Office focused on core activities leading up to and following the October 2019 election. Ministers, parliamentary secretaries and ministerial staff typically experience high turnover around general elections. We assisted those leaving office with their post-employment obligations under the Act and helped new appointees achieve compliance. We released five investigation reports, including the Trudeau II Report under the Act. Like all of our investigation reports, it was prepared with due diligence and dispatch. For me, it is proof of the robustness of Canada's accountability framework, which allows the federal conflict of interest regimes to be enforced regardless of who the subject of an investigation is. We lau​nched a new, mobile-friendly website aimed at better educating and informing stakeholders and the public about those regimes. It is just one component of a new communications approach that is currently under development. We continued to support transparency by publishing quarterly statistical reports on our activities. We recognize that COVID-19 has made for a challenging time in Canada and around the world, and our thoughts are with everyone affected by the pandemic. I remain honoured to serve Parliament and Canadians. I recognize that I am only able to do so because of the hard work and dedication of our employees, and I extend my gratitude to each and every one of them.​​ Mario DionConflict of Interest and Ethics Commissioner Our vision Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament. Our mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.​ Our stakeholders The Office's stakeholders include not only regulatees, namely the individuals who are subject to the conflict of interest regimes it administers, but also Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report touches on all stakeholder groups, but its focus is the public office holders who are subject to the Conflict of Interest Act. The Office's quarterly statistical reports provide an accurate reflection of the fluctuations that occur throughout the year. The following graphic provides a snapshot of public office holders on March 31, 2020. On March 31, 2020, there were 2,668 public office holders of which: 2% (76) are ministers and parliamentary secretaries20% (543) are Governor-in council appointees25% (669) were ministerial staff52% (1,380) are public office holders without reporting obligations. They are part-time members of federal boards, commissions and tribunals, and ministerial staff members who work on average less than 15 hours a week. Ministers and parliamentary secretaries are also subject to the Conflict of Interest Code for Members of the House of Commons. Ministers, parliamentary secretaries, ministerial staff members who work on average 15 hours or more a week and full-time Governor-in-Council appointees such as deputy ministers, heads of Crown corporations and full-time members of federal boards made up the 1,288 reporting public office holders. Additional rules apply to reporting public office holders who are ministers, parliamentary secretaries or ministerial staff members. Public office holders Individuals subject to the Act are collectively known as public office holders. They are all subject to the Act's core set of conflict of interest and post-employment rules. Those rules set out obligations aimed at preventing conflicts between private and public interests and prohibit various activities that could give rise to such conflicts. Just over half of these individuals (52%) do not have ongoing reporting obligations and are subject to the rules set out in Part 1 of the Act.​ These individuals are subject only to those general rules and are referred to as “public office holders without reporting obligations." Additional rules set out in Part 2 of the Act include ongoing reporting and public disclosure provisions, as well as prohibitions against engaging in outside activities and holding controlled assets. The subset of individuals (47%) to whom this section applies are known as “reporting public office holders." Who are reporting public office holders? Ministers*Ministers of state*Parliamentary secretaries*Ministerial staff members who work on average 15 hours or more a weekFull-time Governor-in-Council appointees such as deputy ministers, heads of Crown corporations and full-time members of federal boards *Additional rules apply to reporting public office holders who are ministers, ministers of state, parliamentary secretaries or ministerial staff members. Who are public office holders without reporting obligations? Part-time members of federal boards, commissions and tribunalsMinisterial staff members who work on average less than 15 hours a week After they leave public office, public office holders are subject to the Act’s post-employment rules set out in Part 3. Some of those rules apply to all public office holders for an indefinite period. Others apply only to former reporting public office holders for a one- or two-year “cooling-off” period following their last day in public office.​ Turnover in 2019-2020: 411 reporting public office holders were appointed or reappointed375 reporting public office holders left office445 public office holders without reporting obligations were appointed or reappointed255 public office holders without reporting obligations left office​ Our achievements Administering the Conflict of Interest Act requires the Office to undertake a number of key activities. The following pages explain these activities and how they were undertaken during fiscal year 2019‑2020. Compliance Helping public office holders and Members of the House of Commons achieve and maintain compliance with the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons constitutes the core work of the Office. To support this, a majority of the Office's resources are dedicated to compliance functions. This includes not only the budget of its Advisory and Compliance division, which accounts for over one third of Office employees, but a portion of the budgets of other divisions as well. For example, the Legal Services division may provide opinions that help inform the decision-making process when the Commissioner provides guidance to public office holders and Members on particular compliance matters. The time spent by the Commissioner dealing with such matters and advising individual public office holders and Members is also a factor in the allocation of resources to the Commissioner's Office. Communications with reporting public office holders are more frequent than with those without reporting obligations. The Office has established a service standard to contact all public office holders within three days of being notified of their appointment or reappointment. In 2019‑2020, the standard was met in 80% of cases, up from 62% the year before. Processes are continuously being improved to ensure the target of 80% is maintained or maybe even surpassed. The Office contacts public office holders when they are first appointed or reappointed (856 communications)once a year (2,045 reminders or reviews)when they leave office (630 communications)​ How does the Office help public office holders comply with the Act? by ensuring they complete the initial compliance process (317 processes)by giving them advice when needed (1,941 instances)by posting declarable information in the public registry (773 postings)​ Initial compliance process​ All reporting public office holders must complete an initial compliance process under the Conflict of Interest Act. This process begins soon after they are appointed or reappointed to public office. The entire process must be completed within 120 days after their appointment or reappointment when there is an interruption between the appointment and reappointment. The Office's compliance advisors and officers guide them through it every step of the way. The Commissioner is kept abreast of files throughout the process. Steps in initial compliance process 317 initial compliance processes completedFirst letter (sent with copy of Act and summary of application of rules)The Commissioner sends a letter to reporting public office holders when the Office is notified of their appointment or reappointment. 411 first letters sentConfidential ReportReporting public office holders must file a Confidential Report outlining their assets, liabilities, income, current and past activities and any other information the Commissioner considers necessary, within 60 days after their appointment or reappointment. On request, advisors and officers help them complete their Confidential Report. Review of Confidential ReportAdvisors review each Confidential Report to inform reporting public office holders on how to meet their initial compliance obligations under the Act. Some matters may require a decision from the Commissioner, and the Legal Services division may be required to provide opinions that help inform the decision-making process. Initial compliance callAdvisors schedule a call (or an in-person meeting) with each reporting public office holder to review the Act’s substantive provisions, including post-employment rules, clarify disclosures in the Confidential Report and provide guidance on necessary measures. These may include the public disclosure of certain information, the divestment of controlled assets (please see below), minimal value exemptions, the establishment of conflict of interest screens, recusals or other measures deemed necessary under section 29 of the Act. Some of these require the Commissioner’s approval.​ 306 initial compliance calls completed 125 declarations of assets 44 declarations of liabilities 85 declarations of outside activities 9 agreed compliance measures, including 8 conflict of interest screensIntermediate letter (sent with Summary Statement and other public declarations)Formalizes the advice provided verbally to the reporting public office holder and any required compliance measures. The Summary Statement and any public declarations prepared by the advisor are included with the letter. The reporting public office holder must sign and return these once all compliance measures are finalized and within 120 days after their appointment or reappointment. 283 summary statements posted in the public registry 50 divestments of controlled assets, including 37 by sale and 13 by blind trustFinal letter sent by Commissioner andpublic registry postingsSignals the completion of the initial compliance process. Information on ongoing reporting obligations, gifts and administrative monetary penalties is enclosed. The Summary Statement and required declarations are posted in the public registry on the Office’s website.​​ ​Reporting public office holders may not hold or acquire controlled assets during their term of office. They must divest any such assets within 120 days after their appointment, by selling them to a third party in an arm’s-length transaction or by placing them in a blind trust. The Office’s website contains several information notices that explain the Act’s divestment requirements, including one on categories of assets that was updated in January 2020. Advisors guide reporting public office holders through the divestment process. Staff in the Corporate Management division review and analyze the costs of​ establishing, administering and dismantling blind trusts and help the Commissioner determine the reasonableness of fees incurred so he may issue orders for reimbursement to the reporting public office holders’ organizations. In 2019-2020, the Commissioner issued 163 orders for reimbursement totalling $777,523.38. Process for public office holders without reporting obligations First letter (sent with copy of Act and summary of application of rules)Provides an overview of the obligations set out in the Act and invites public office holders without reporting obligations to contact the Office for confidential advice on conflict of interest matters.​ ​ 445 first letters sentAnnual reminderAn annual letter reminds them of the Act’s conflict of interest rules. 1,475 annual reminders sentPost-employment letterOnce they leave office, the Office sends them a letter detailing their post-employment obligations. 255 post-employment letters sent Ongoing reporting requirements After they have completed the initial compliance process, reporting public office holders must meet a number of reporting requirements throughout their terms of office. Some of these requirements may also apply to public office holders without reporting obligations. Some are subject to administrative monetary penalties for failure to meet them within the timeframe established in the Act. Annual reviewThe Commissioner must review the disclosures of reporting public office holders every year and update information previously disclosed. 570 annual reviews initiated and 564 received General obligations​Since compliance with the Act is a condition of all public office holders’ appointment or employment, they are encouraged to contact the Office about all questions regarding their obligations. 416 requests for advice on general obligationsMaterial changes (subject to a monetary penalty)Reporting public office holders must inform the Office of any material change to any matter they were required to disclose during the initial compliance process, within 30 days after the change. In February 2020, the Office published an updated information notice on material change and issued a Notice of Material Change form to facilitate compliance with this requirement. 603 requests for advice on material ​changesGifts or other advantages Reporting public office holders must publicly declare any acceptable gifts or other advantages they or their family members accept from any one source in a 12-month period with a value of $200 or more. A disclosure to the Office must also be made within 30 days after the day on which the cumulative value of multiple gifts exceeds $200. Unless the Commissioner determines otherwise, all gifts received by a public office holder as an expression of courtesy or protocol valued at $1,000 or more must be forfeited to Her Majesty in right of Canada and so disclosed in the public registry. 236 requests for advice and 166 public declarations of gifts or other benefits Private flightsMinisters, ministers of state and parliamentary secretaries must publicly declare, within 30 days, any travel on non-commercial chartered or private aircraft accepted for themselves, their families or ministerial staff or advisers. These individuals can only accept such travel if required in their capacity as public office holders, in exceptional circumstances or with the Commissioner’s prior approval. 6 declarations of travel on non-commercial chartered or private aircraftRecusals All public office holders 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. Reporting public office holders must publicly declare any recusal, within 60 days after the day on which the recusal takes place. A conflict of interest screen may be established if conflicts of interest are likely to recur. ​10 public declarations of recusalsPost-employment obligationsReporting public office holders must disclose to the Office all firm offers of outside employment, within seven days after receiving them. They must also disclose to the Office the acceptance of offers of outside employment, within seven days after accepting them. Once public office holders leave office, they are all subject to some rules that have no time limit. Reporting public office holders are also subject to more stringent rules during a cooling-off period of two years for ministers and one year for other reporting public office holders. Depending on the situation, they may apply to the Commissioner for a waiver, reduction or exemption. 386 requests for advice on post-employment obligations including firm offers of outside employment and acceptance of offers of outside employment 375 post-employment letters sent 13 post-employment waivers or exemptions The Office communicates with regulatees in their preferred official language, as indicated by the Privy Council Office for Governor-in-Council appointees and by ministers’ offices for ministerial staff. Regulatees may also inform the Office whether they wish to communicate in English or French. Public registry Transparency is a pillar of effective conflict of interest regimes. In this context, it means openness, clarity, unobstructed access and disclosures when interacting with, or on behalf of, the public. The conflict of interest regimes administered by the Office ensure transparency through disclosure and public declaration requirements. The Office maintains a public registry of compliance documents required under the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. It is a searchable database that contains public office holders' summary statements, as well as their public declarations relating to gifts or other advantages, travel, certain assets and liabilities, outside activities and other declarations as necessary.​ In 2019-2020, public office holders declared 6 instances of travel9 agreed compliance measures9 administrative monetary penalties10 recusals11 others12 compliance orders13 post-employment exemptions, waivers or reductions44 liabilities85 outside activities125 assets166 gifts or other advantages283 summary statements​ Direction and advice​ To help public office holders comply with the Conflict of Interest Act, the Office provides them with confidential direction and advice tailored to their individual situations. It continues to follow the processes developed since the coming into force of the Act and the interpretative approach taken by the Commissioner in the last two years to ensure coherence in the application of the rules set out in the Act. All public office holders must be able to feel confident the advice they are given is fair and appropriate. This is reflected in the Office's mission statement and is the objective of several projects within the Office's three-year strategic plan. Public office holders frequently consult the Office, either during or after their term of office. The Commissioner personally met with over 40 regulatees to discuss their personal situation, in addition to any communications public office holders had with their advisors. They ask about a range of matters, such as how to arrange their affairs to comply with the Act, how to make a public declaration and how to meet their post-employment obligations. Questions about material changes accounted for one third of the requests for advice received in 2019-2020.​ In 2019-2020, public office holders asked about gifts or other advantages (12%)outside activities (15%)post-employment obligations (20%)general obligations (21%)material changes (31%) Education and outreach The Office conducts a range of education and outreach activities to help public office holders understand and meet their obligations under the Conflict of Interest Act. They supplement the confidential advice and direction provided to individual public office holders and other communications regarding compliance processes. ​ Information notices These educational tools explain how various provisions of the Act apply and, where relevant, the ​​Commissioner's interpretations of them. All information notices are posted on the Office's website and some are accompanied by videos which are also available on its YouTube channel, Ethics Canada. In 2019-2020, the Office issued 12 updated or new information notices: Three rules summaries for public office holders, reporting public office holders, and ministers and parliamentary secretariesEight on compliance requirements for reporting public office holders, categories of assets, conflict of interest screens, material change, participation in appointment processes, recusal obligations, administrative monetary penalties and investigations under the ActOne on the Commissioner's role and mandate Presentations Most are delivered in-person by the Commissioner and staff and six were delivered via teleconference. By using teleconference and webinar technology to deliver presentations, the Office can reach a greater number of regulatees.​ A total of 28 presentations were given to offices and organizations with regulatees subject to the ActTotal of 514 participants​ Social ​media The Office uses Twitter (@EthicsCanada) to communicate directly with regulatees, for example by tweeting links to updated or new information notices. The Office tweeted 171 times about its activities, role and mandate Enforcement​ While prevention is its major focus, the Office does not hesitate to apply the enforcement provisions of the Conflict of Interest Act as appropriate. Administrative monetary penalties The Commissioner can impose administrative monetary penalties of up to $500 for failures to meet certain reporting requirement​s of the Act within the established deadlines. These include Confidential Report filings, disclosures of material changes, firm offers of outside employment and their acceptance, and public declarations of gifts and recusals. In 2019-2020, the Commissioner did so in nine c​​​ases. When a penalty is issued, the Act requires that the Commissioner make public the nature of the violation, the name of the public office holder and the amount of the penalty. Accordingly, the Office posts them in the public registry. It also makes ​reference to penalties on Twitter soon after they are added to the registry. Compliance orders Under section 30 of the Act, the Commissioner may order a public office holder to take any compliance measure that the Commissioner determines is necessary to comply with the Act, such as submitting documents for the annual review, ceasing prohibited outside activities or divesting any assets that could give rise to a conflict of interest.​ In 2019-2020, four administrative penalties were issued for failures to submit a Confidential Report within the 60-day deadline and five were issued for failures to report material changes.​ The Office faced an unprecedented compliance situation after the Canadian Energy Regulator Act (CER Act), which established the Canadian Energy Regulator, became law in June 2019. Sections 16, 22 and 29 of the CER Act set out the circumstances in which the Canadian Energy Regulator's chief executive officer, directors and commissioners, who are subject to the Conflict of Interest Act as public office holders and reporting public office holders, are understood to be in a conflict of interest for the purposes of the Conflict of Interest Act. They expand the meaning of conflict of interest beyond what exists in the Conflict of Interest Act by prohibiting certain outside activities and holdings. The Commissioner responded by issuing section 30 compliance orders to the Canadian Energy Regulator's chief executive officer, directors and commissioners to ensure they are not in a conflict of interest under the CER Act. This was the first time the Conflict of Interest and Ethics Commissioner had to issue a compliance order to ensure that public office holders comply with a broader definition of conflict of interest. Examination case files When the Office receives information about a possible contravention of the Act, including through media reports or complaints from members of the public, a case file is opened. The information is reviewed to determine whether the concern raised falls within the Office's mandate and, if it does, whether the Senator or Member of the House of Commons set out reasonable grounds to believe—or, in the case of a self-initiated examination, whether the Commissioner has reason to believe—that a contravention may have occurred. Some of these initial reviews lead to examinations. In other cases, an examination is not found to be warranted and the files are closed.​ A case file is a concern reviewed by the Office. In 2019-2020, it reviewed 50 case files. 31 case files were closed without an examination16 case files are ongoing3 case files were closed with the publication of a report ​The Office reviewed these 50 case files based on the followin​g sources: a Member of the House of Commons (2)the media (3)a referral from the Public Sector Integrity Commissioner (5)within the Office (11)​​a member of the general public (29)​ The breakdown of the nature of these con​​cerns is as follows: There were 28 concerns about “furthering a private interest."There were eight concerns about “influenc​e."​There were eight concerns about post-employment rules.There were three concerns about “insider information."There were two concerns about the duty to recuse. The subjects of these case files were as follows: Current or former ministers or parliamentary secretaries were the subject of case files in 28 instances.Other current or former public office holders were the subject of case files in 47 instances.Persons not subject to the Act were the subject of case files in two instances.​ Examinations The Commissioner can launch an examination of a possible contravention of the Conflict of Interest Act at the request of a Senator or Member of the House of Commons who provides reasonable grounds to believe the Act has been contravened. The Act also gives the Commissioner the discretion to conduct an examination on his own initiative if the Commissioner has reason to believe the Act has been contravened. Decisions to do so may be based on information that comes to the attention of the Office in various ways, including media reports and complaints from members of the public. The Commissioner issues a public report upon the completion of an examination. When the Commissioner decides to discontinue an examination launched in response to a request from a Senator or Member, a discontinuance report is issued. Matters may also be referred to the Commissioner by the Public Sector Integrity Commissioner under subsection 24(2.1) of the Public Servants Disclosure Protection Act. When such a referral is received, the Commissioner is required, under section 68 of the Conflict of Interest Act, to issue a report, which is made public. The report must set out the facts in question, the analysis of the situation and the conclusion, whether or not an examination is launched. In 2019-2020, the Office issued two examination reports under the Conflict of Interest Act: In the Smolik Report, issued on May 30, 2019, the Commissioner found that Mr. Jim Smolik, a former Assistant Chief Commissioner and Acting Chief Commissioner of the Canadian Grain Commission, contravened two of the Act's post-employment provisions when he engaged in several interactions with the Commission on behalf of his new employer, Cargill Limited. Mr. Smolik was found to have contravened section 33 of the Act, which prohibits former public office holders from acting in such a manner as to take improper advantage of their previous office. This rule applies for an indefinite period. The evidence showed he exploited his previously established Commission relationships and the knowledge and expertise he had acquired while employed at the Commission to help Cargill obtain a timely and favourable decision from the Commission. Mr. Smolik was also found to have contravened subsection 35(2) of the Act. This provision prohibits former reporting public office holders from making representations for or on behalf of any other person or entity to any department, organization, board, commission or tribunal with which they had direct and significant official dealings during their last year in public office. Representations include communications made with a view to influencing official decisions, opinions or actions. For Mr. Smolik, this rule applied for a cooling-off period of one year following his last day in office. As a former Commissioner of the Canadian Grain Commission, Mr. Smolik had direct and significant official dealings with the Commission during his last year in public office. The evidence showed that an application by Cargill to the Commission, which was submitted by Mr. Smolik during his cooling-off period, was a communication made by him to the Commission with a view to influencing a decision or action. In the Trudeau II Report, issued on August 14, 2019, the Commissioner found that the Right Honourable Justin Trudeau, Prime Minister of Canada, contravened section 9 of the Act when he used his position to seek to influence a decision of the Attorney General of Canada relating to a criminal prosecution involving SNC-Lavalin. Section 9 prohibits public office holders from using their position to seek to influence a decision of another person so as to further their own private interests or those of their relatives or friends, or to improperly further another person's private interests. The decision in question was whether or not the Minister of Justice and Attorney General, the Honourable Jody Wilson-Raybould, should intervene in the Director of Public Prosecutions' September 2018 decision not to invite SNC-Lavalin, which was facing criminal charges, to negotiate a possible remediation agreement. The Commissioner determined that Mr. Trudeau, either directly or through the actions of those under his direction, sought to influence the Attorney General's decision as to whether she should intervene in SNC-Lavalin's criminal prosecution. He further determined that Mr. Trudeau, through his actions and those of his staff, sought to do so improperly. The evidence showed that SNC-Lavalin had significant financial interests that would likely have been furthered had Mr. Trudeau successfully influenced the Attorney General. The actions that sought to further these interests were improper since they were contrary to the principles of prosecutorial independence and the rule of law. The Office also issued a report as a result of a referral made by the Public Sector Integrity Commissioner: In the Wernick Report, issued on March 10, 2020, the Commissioner concluded that he did not have reason to believe that Mr. Michael Wernick had contravened the Act while he was Clerk of the Privy Council and Secretary to the Cabinet, and would therefore not pursue the matter further. It was alleged that Mr. Wernick may have contravened section 9 of the Act in matters raised during the Trudeau II Report investigation. In that examination, the Commissioner concluded that the individuals who acted under the direction or authority of the Prime Minister could not have influenced the Attorney General simply by virtue of their position. This conclusion applied to a number of reporting public office holders, including Mr. Wernick. Barring exceptional circumstances, the Office's target is to conduct examinations within a 12‑month timeframe. As of March 31, 2020, the Office was working on 12 other examinations under the Act, 10 of which relate to the same subject matter. The nature of those examinations has not been made public. Four case files were also under review. The Office is often asked for information about examinations that are in progress, but strict confidentiality requirements set out in the Act prevent it from providing any information. The Commissioner believes the Act continued to work well in 2019-2020. He could, however, offer a few suggestions on possible amendments should Parliament decide to review the legislation. ​ Public communications In 2019-2020, the Office continued to undertake a range of public communications initiatives. They are aimed at educating and informing regulatees, as well as the media and the general public, about Canada's federal conflict of interest regimes and the Office's role in administering them. The Office started developing a communications approach that identifies a range of actions in support of one of the key priorities identified in its strategic plan: building and improving communications and outreach processes. Website: 66,870 visi​tors In October 2019, the Office launched a new website aimed at better educating and informing r​egulatees, the media and the public. Designed to make information more easily accessible in the interests of transparency and accountability, it has improved functionality and is more mobile-friendly, making it a more effective source of information. Social media: 1,245 followers Twitter (@EthicsCanada) is used to communicate information about the Office and its work. Items of interest to the Office and the ethics community at large, such as relevant reports from other Canadian conflict of interest commissioners and international organizations, are retweeted. In 2019-2020, the number of followers grew by 22%, increasing the Office's social media reach. The new communications approach includes a detailed social media plan. Media and public inquiries: 175 media and 1,608 public Recognizing the important role the media play in promoting awareness of the Commissioner’s role ​and mandate and the need to help them report as accurately as possible, the Office has continued to provide them with as much information as it is permitted to. It issues media advisories and news releases and shares information via Twitter in addition to responding to media and public inquiries. The Commissioner participated in six interviews with journalists in 2019-2020. ​ Presentations: 11 presentations and 584 participants The Commissioner and representatives of the Office give a variety of presentations to help Canadians and international audiences understand the role and mandate of the Office. Where possible, participants have access to an Internet-based audience interaction tool that enables audience members to use their mobile devices to anonymously ask questions and participate in live polls. In May 2019, a senior representative of the Office gave a presentation to The Many Facets of Parliament event for parliamentary employees. In October, the Commissioner met with Parliamentary Internship Programme participants and led a discussion with political science students at the University of Ottawa. The Commissioner also gave presentations to Ontario Legislative Internship Programme students in December, and to a class at Carleton University in February 2020. That same month, he participated in the Conference Board of Canada's Public Sector Leadership Conference. The Office receives a large volume of inquiries from members of the public. When responding, it takes the opportunity to educate them about the Commissioner's role and mandate. When their concerns do not fall within the mandate of the Office, they are directed to other organizations that might be better able to assist them. The Office received 1,783 communications from the media and the public in 2019-2020. The Office strives to respond to such communications in a timely manner and has established service standards to do so. The target for achieving those service standards was set at 80%. Media requests were responded to within four hours in 86% of cases. Communications from members of the public were responded to within two weeks in 80% of cases. In 2019-2020, in support of its values of equality, respect and inclusiveness, the Office started using gender-inclusive language in its communications. Collaboration and best practices The Office continued to work with counterparts in Canada and other countries in 2019-2020, exchanging information about conflict of interest rules and practices and discussing related issues in order to stay abreast of evolving concerns and new developments in the field. Domestic Outreach In September 2019, senior Office representatives attended the annual meeting of the Canadian Conflict of Interest Network (CCOIN), held in Regina, Saskatchewan. Formed in 1992, CCOIN is made up of conflict of interest commissioners at the federal level and from all Canadian provinces and territories. The Office has coordinated information gathering for CCOIN since 2010. In February 2020, the Office hosted a working meeting with the Quebec Ethics Commissioner and members of her staff. Employees in all divisions participated in briefings about Office activities and approaches in compliance, investigations, communications, strategic planning and other areas. The Office has continued to implement the March 2018 memorandum of understanding that the Commissioner signed with the Commissioner of Lobbying to cooperate on education and outreach and to jointly organize educational activities for individuals affected by the work of both offices. In 2019‑2020, the two commissioners cohosted six teleconferences in which a total of 292 public office holders participated. Two teleconferences, one in English and the other in French, were held with reporting public office holders on their post-employment obligations in November 2019. These were repeated in January 2020 for those who were unable to participate earlier. In March 2020, separate English and French teleconferences were held for ministerial staff. The Commissioner meets regularly with other agents of Parliament to discuss common challenges and ways of meeting them and to listen to presentations of interest to all. Likewise, Office employees liaise with their counterparts in the offices of other agents of Parliament. For example, staff in the Communications, Outreach and Planning division attend regular meetings of an agents' communications group. Staff in the Legal Services division are part of an agents' legal services group that organized a one-day seminar in May 2019 for all lawyers in those offices.​ International outreach In 2019-2020, the Office remained active in the network of conflict of interest and parliamentary ethics organizations within the Organisation internationale de la Francophonie. The Réseau parlementaire, which the Commissioner helped found in 2018, seeks to foster the sharing of best practices among commissioners and other ethics and conflict of interest bodies. In October 2019, a senior Office representative attended a meeting of the group in Namur, Belgium. In December 2019, a senior Office representative made a presentation on the Commissioner's behalf at the 7th Global Conference of Parliamentarians Against Corruption. The event, organized by the Global Organization of Parliamentarians Against Corruption, took place in Doha, Qatar. In December 2019, Office representatives attended the annual conference of the Council on Governmental Ethics Laws (COGEL) in Chicago, at which a senior Office representative participated in a panel discussion about compliance communications. COGEL is a U.S.‑based, international not-for-profit organization of government ethics practitioners. The Office is a member and other Canadian conflict of interest and integrity offices are also active in it. The Office was scheduled to participate in the Organisation for Economic Co-operation and Development's Global Anti-Corruption and Integrity Forum in Paris in March 2020, but the event was cancelled because of the COVID-19 pandemic. International counterparts sometimes approach the Office to organize delegation visits. During such visits, the Office provides an overview of the Canadian ethical framework and explains the role and mandate of the Office. They are also an opportunity for the Office to learn firsthand about the ethics regimes in other countries. In December ​2019, it hosted a delegation from the Ministry of Personnel Management of the Republic of Korea.​ Contacts with Parliament The Conflict of Interest and Ethics Commissioner is an independent officer of the House of Commons who reports directly to Parliament, through the Speaker of the House of Commons, on behalf of Canadians. The Commissioner is required to submit an annual report on the administration of the Conflict of Interest Act to Parliament by June 30 for tabling with the Speakers of the Senate and the House of Commons. He reports on examinations under the Act to the Prime Minister. The Commissioner also testifies before parliamentary committees about the Office and its work. On May 16, 2019, he appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics about the Office's budgetary submission for the 2019‑2020 Main Estimates. The Committee has oversight responsibility for the Office and reviews its annual spending estimates, as well as matters related to reports under the Act. The Commissioner had been invited to appear before the House of Commons Standing Committee on Access to Information, Privacy and Ethics in March 2020. However, the committee meeting was delayed because of the COVID-19 pandemic. Our tools The success of the Office's mission is supported by its people and its infrastructure. Because the Office is a small organization, it has the flexibility to respond quickly to changes in the external environment. Our people The accomplishments of the Office depend on the hard work and dedication of employees at all levels. Commissioner Dion has complete confidence in the senior management team and indeed in all Office employees. They produce work of consistently high quality, demonstrate rigour and professionalism and act with integrity at all times. The Commissioner 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, and they ensure that all reasonable measures are provided for their safety and security. The terms and conditions of employment were updated in 2019-2020 to ensure they are in line with those of other parliamentary entities and the federal public service. The Office shares similar values with the public service and parliamentary entities. All Office employees are expected to follow the values—respect for people, professionalism, impartiality and integrity—set out in the Office's Code of Values and Standards of Conduct. These key documents were also updated in 2019-2020. The Quality Workplace Promotion Committee continued to coordinate initiatives to promote employees' well‑being. These included a two-day mental health first aid course offered by the Canadian Mental Health Association; participation was mandatory for directors and managers. The course was to be held twice in order to accommodate all participants, but the second session was postponed because of the COVID‑19 pandemic. Our infrastructure The Office has a sound internal management framework in place to ensure the prudent stewardship of public funds, the safeguarding of public assets and the effective, efficient and economical use of resources. Because the Commissioner is an independent officer of the House of Commons and the Office is a parliamentary entity, it is not generally subject to legislation governing the administration of the public service or to Treasury Board policies and guidelines. It tries to ensure that its resource management practices are, to the greatest extent possible, consistent with those found in the public service and in Parliament. The Office also looks at policies and practices of other parliamentary entities and generally follows what they do, unless there is a valid reason to take a different approach. The Office's financial statements are audited each year by an independent external auditor. The Financial Resources Summary appended to this report outlines its financial information for the 2019‑2020 fiscal year. In March 2020, the Office organized a two-day occupational health and safety training course for its Work Place Health and Safety Committee and employees whose duties and responsibilities have an occupational health and safety component. Finally, to support efforts to limit the spread of COVID‑19, in March 2020, the Commissioner suspended in-office operations and assigned all staff to telework. Thanks to measures put in place earlier and support from the House of Commons information technology group, the Office was well equipped to continue to achieve its mission under modified working conditions. Measures completed in 2019-2020 included the replacement of remaining desktop computers with laptops and tablets and the development of a pilot telework policy. The Office of the Conflict of Interest and Ethics Commissioner comprises the following divisions: Commissioner's Office (4 employees)Advisory and Compliance (19 employees)Investigations and Legal Services (8 employees)Communications, Outreach and Planning (8 employees)Corporate Management (11 employees)​ Our challenges External developments can impact the way the Office implements its mandate. All of these challenges are opportunities that carry the potential for positive change. Safeguarding the public trust​ Gaining and retaining public trust remains an ongoing challenge for institutions in Canada. This is evidenced by data published by credible international organizations that provide a broad indication of levels of public trust in Canada. Transparency International's Corruption Perceptions Index ranks 180 countries and territories by their perceived levels of public sector corruption. In the 2019 index, Canada ranked as the 12th least corrupt country in terms of public perception, three positions behind its 9th place ranking in 2018. The Edelman Trust Barometer is an annual survey that explores trust in business, government, non-governmental organizations and media across 28 global markets. According to its latest edition, released in February 2020, public trust in Canada slipped just below the global average in the past year. Although overall trust levels have dipped slightly, these results demonstrate that Canadians place a great deal of importance on the integrity of their institutions. Transparency and public trust interact in complex ways. In a democratic society, the latter cannot exist without the former. Yet when transparency allows light to be shined on instances of conflicts of interest, no matter how minor they might be, the public trust tends to erode. At the same time, the more issues of public integrity become salient, the better the public understands that safeguarding democratic institutions is a perpetual endeavour. It is encouraging to note that more than half of the concerns the Office reviewed in 2019-2020 came from the general public. There are advantages in harnessing public scrutiny to strengthen the Office's compliance mechanisms. After all, the public has the most to lose when the checks and balances of democracy are not respected. Hence, the Office will continue to improve its outreach and education to ensure Canadians have the tools and understanding necessary to participate in safeguarding the public trust. Effective oversight​ The Office can administer the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons more effectively when public office holders and Members of the House of Commons reach out to the Office before taking actions or engaging in activities that could potentially lead to a contravention of the applicable regime. Such knowledge could enable the Office to direct and advise them on how to deal with those situations in order to maintain compliance and avoid any loss of public trust. While the Office has come across information indicating potential contraventions from time to time, it has not historically conducted any active oversight. Such information also allows the Office to apply the regimes' enforcement provisions as appropriate. In 2019-2020, initial steps were taken to staff a new data analyst position in the Communications, Outreach and Planning division to help the Office improve its oversight. Monitoring of sources of public information will be conducted, particularly for positions that have been evaluated as potentially having a higher risk of conflict of interest. The need to ensure effective oversight has become even more important as a result of the COVID-19 pandemic. In such an extraordinary situation, complying with the Act and the Code may, understandably, not be top of mind for public office holders and Members. Court matters​ Matters involving the Office have been the object of several applications for judicial review. While dealing with them can consume a significant amount of Office resources, they can also be opportunities to clarify the Commissioner's mandate and powers.​ Court matters can also be opportunities to clarify the Commissioner’s mandate and powers. Democracy Watch v. Canada (Attorney General), 2020 FCA 28: The Federal Court of Appeal dismissed Democracy Watch's appeal of a decision by the Federal Court of Canada (2018 FC 1290) in respect of the appointment of the Conflict of Interest and Ethics Commissioner. The appellant argued that the Governor in Council failed in its duty to adequately consult with leaders of the recognized parties prior to the nomination and subsequent appointment of the Commissioner, Mario Dion, in 2017. The appellant also argued that the Governor in Council was biased in its decision, since there were members of Cabinet under examination at the time of appointment. In its reasons provided from the Bench, the Court was not persuaded that the consultation process had been unreasonable and that the nature of the legislative scheme to appoint a commissioner made the appearance of bias “inevitable." Democracy Watch has publicly stated that it intends to seek leave to appeal to the Supreme Court of Canada. Democracy Watch v. Canada (Attorney General) (A-331-19): Democracy Watch filed an application for judicial review challenging the Commissioner's findings in the Trudeau II Report. The applicant seeks to quash the findings of the report on the basis that the Commissioner erred in law, failed to exercise his jurisdiction and failed to observe a principle of natural justice by not acknowledging a request for examination received by Ms. Elizabeth May, Member of Parliament for Saanich–Gulf Islands. The applicant further argues that the Commissioner, who was appointed by the Governor in Council, failed to exercise his jurisdiction and exhibited a reasonable apprehension of bias in his decision not to examine the conduct of other public office holders involved in the matter. Democracy Watch v. Canada (Attorney General) (A-434-19): The Federal Court of Appeal struck out Democracy Watch's application for judicial review challenging the Commissioner's findings in the Trudeau II Report. The applicant had previously filed a separate challenge (A-331-19) of the same examination report on the basis that the Commissioner had not properly considered a request for examination received from Ms. Elizabeth May, Member of Parliament for Saanich–Gulf Islands. When the applicant was informed that the Commissioner had indeed responded to Ms. May's request for an examination of the matter, the applicant attempted to judicially review that communication as well. The Court dismissed the second application on the grounds that it was statute-barred, that the Court was already seized with an application challenging the same matter and seeking the same remedy, and that the applicant lacked public interest standing to raise the issue. Democracy Watch v. Attorney General of Canada, et al., 2019 (SCC 38455): The Supreme Court of Canada dismissed without costs Democracy Watch's application for leave to appeal a decision issued by the Federal Court of Appeal (2018 FCA 194) upholding the Commissioner's authority under the Conflict of Interest Act to determine that a conflict of interest screen is an ap​propriate compliance measure falling within the ambit of section 29 of the Act. Appendix Financial resources summary ​(thousands of dollars)​​​​Program Activity ​2018-2019 Actual Spending 2019-2020 ​Alignment toGovernment of CanadaOutcomes​ ​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​​ ​ 5,827 ​ 6,356 ​ 6,356 ​ 6,199 ​Government Affairs​Contributions to employee benefit plans​691​787​787​687​​Total spending​6,5187,1437,1436,886​​Plus: cost of services received without charge​1,110​n/a​n/a​1,134​ ​Net cost of department​​​ ​7,628​7,143​7,143​8,020​​​​ The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on our Office's effectiveness, management and operations, together with its operational and expenditure plans. The figures in this summary have not been audited. Complete audited financial statements will be available on our website.

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 my 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, 2020, 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, Mario DionConflict of Interest and Ethics Commissioner Commissioner's message I am pleased to report on the administration of the Conflict of Interest Code for Members of the House of Commons (Code) in 2019-2020. It was an eventful and productive year. Preparing for and dealing with the increased workload that typically results from general elections was a key focus for the Office in administering the Code. Indeed, almost 30 per cent of Members of the House of Commons elected in October 2019 did not hold seats in the previous Parliament. All Members, newly elected and returning alike, are required to complete the initial compliance process under the Code. We released two investigation reports under the Code. Like all of my investigation reports, they were prepared with due diligence and dispatch. For me, they are proof of the robustness of Canada's accountability framework. It allows the federal conflict of interest regimes to be enforced even when the subject of an investigation is an elected Member. Investigation reports are also an opportunity to educate Members and the public. We launched a new, mobile-friendly website aimed at better educating and informing stakeholders and the public about those regimes. It is just one component of a new communications approach that is currently under development. We continued to support transparency by publishing quarterly statistical reports on our activities. We recognize that COVID-19 has made for a challenging time in Canada and around the world, and our thoughts are with everyone affected by the pandemic. I remain honoured to serve Parliament and Canadians. I recognize that I am only able to do so because of the hard work and dedication of our employees, and I extend my gratitude to each and every one of them. Mario DionConflict of Interest and Ethics Commissioner Our vision Offer exemplary services in support of a culture of integrity in order to achieve a high degree of public confidence in the integrity of federal institutions and Parliament. Our mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. Our stakeholders The Office's stakeholders include not only regulatees, namely the individuals who are subject to the conflict of interest regimes it administers, but also Parliament, academics, ethics practitioners and others with an interest in the field, the media and the general public. This report touches on all stakeholder groups, but its focus is the Members of the House of Commons who are subject to the Conflict of Interest Code for Members of the House of Commons. The Office's quarterly statistical reports provide an accurate reflection of the fluctuations that occur throughout the year. The following graphic provides a snapshot of Members on March 31, 2020. On March 31, 2020, there were 338 elected Members of the House of Commons of which: 37 (11%) were ministers39 (12%) were parliamentary secretaries262 (77%) were Members of the House of Commons who are not ministers or parliamentary secretaries Ministers and parliamentary secretaries are also subject to the Conflict of Interest Act. Our achievements Administering the Conflict of Interest Code for Members of the House of Commons requires the Office to undertake a number of key activities. The following pages explain these activities and how they were undertaken during fiscal year 2019‑2020. Compliance Helping Members of the House of Commons and public office holders achieve and maintain compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act constitutes the core work of the Office. To support this, a majority of the Office's resources are dedicated to compliance functions. This includes not only the budget of its Advisory and Compliance division, which accounts for over one third of Office employees, but a portion of the budgets of other divisions as well. For example, the Legal Services division may provide opinions that help inform the decision-making process when the Commissioner provides guidance to Members and public office holders on particular compliance matters. The time spent by the Commissioner dealing with such matters and advising individual Members and public office holders is also a factor in the allocation of resources to the Commissioner's Office. The Office's contact with Members starts shortly after their election or re-election and is maintained throughout their time in office. How does the Office help Members comply with the Code? by contacting them as soon as they are elected (339 communications)by ensuring they complete their initial compliance process (75 processes)by giving them advice when they need it (476 instances)by contacting them annually (84 reviews)by posting their information in the public registry (251 reviews) Initial compliance process All Members must complete an initial compliance process under the Conflict of Interest Code for Members of the House of Commons. It begins soon after they are elected or re-elected in a general election or by-election. The Office's compliance advisors and officers guide them through it every step of the way. The Commissioner is kept abreast of all Members' files throughout the process. STEPS IN INITIAL COMPLIANCE PROCESS 75 initial compliance processes completedFirst letter (sent with copy of Code and other supporting documents)The Commissioner sends a letter to Members when notice of their election or re-election is published in the Canada Gazette. 339 first letters sentConfidential Disclosure StatementMembers must file a confidential Disclosure Statement of detailed information on assets, liabilities, trusts, income, outside activities and other interests for themselves and their immediate family members. They must submit their Disclosure Statement and supporting documents, such as financial statements, to the Office no later than 60 days after notice of their election or re-election is published in the Canada Gazette. On request, advisors and officers help Members complete their statement. Review of confidential Disclosure StatementAdvisors review the information in the disclosure statements to inform Members about how to meet their initial compliance obligations under the Code. Some matters may require a decision from the Commissioner, and the Legal Services division may be required to provide opinions that help inform the decision-making process. 339 confidential disclosure statements receivedInitial compliance callAdvisors schedule a call (or an in-person meeting) with each Member to discuss their substantive obligations under the Code and give them a detailed overview of their ongoing obligations. Advisors may request additional information to clarify or confirm the information provided. They also notify Members of the information that will require public disclosure. 93 initial compliance callsIntermediate letter (sent with Disclosure Summary)Advisors prepare disclosure summaries. Each Member has 60 days to review and sign their Disclosure Summary. 164 disclosure summaries preparedFinal letter sent by Commissioner and public registry postingsSignals the completion of the initial compliance process. Information on ongoing reporting obligations such as gifts and sponsored travel is enclosed. The Disclosure Summary is then placed on file at the Office and posted in the public registry on the Office’s website. The Office maintains a Members' Compliance Status Report that identifies where each Member is in the initial compliance process on a specific day. It is updated as required, and more frequently after general elections, and is available on the Office website. On March 31, 2020, 269 Members who were elected or re-elected in October 2019 were still in the process of completing the initial compliance process. Ongoing reporting requirements After they have completed the initial compliance process under the Conflict of Interest Code for Members of the House of Commons, Members must meet a number of reporting requirements throughout their time in office to remain in compliance. They are encouraged to contact the Office at any time if they have questions about their obligations. Annual review Members must file a full Disclosure Statement 60 days after the date established by the Commissioner for their annual review. This marks a change from the previous annual review process to better reflect the requirement in paragraph 20(1)(ii) of the Code. The Office made the change after the October 2019 election. 84 annual reviews initiated and 119 received General obligationsMembers are encouraged to contact the Office about all questions regarding their obligations. 190 requests for advice on general obligationsMaterial changesMembers must file a Notice of Material Change form within 60 days after the change to inform the Office of any material change to the information in their Disclosure Statement. The Office will determine if any measures must be taken and if the Disclosure Summary needs to be amended. 144 requests for advice and 10 public declarations of material changeGifts or other benefitsMembers must publicly declare any acceptable gifts or other benefits they or their family members accept from any one source in a 12‑month period with a value of $200 or more. A Public Statement of Gifts or other Benefits form must also be filed within 60 days after the day on which the cumulative value of multiple gifts from the same source exceeds $200. 100 requests for advice and 45 public declarations of gifts or other benefitsSponsored travelMembers who are not ministers or parliamentary secretaries may accept, for themselves and their guests, sponsored travel related to their position. They must file a Public Statement of Sponsored Travel form within 60 days after the end of the trip. To assist Members with procedures for disclosing sponsored travel they have accepted, the Office created, in March 2020, a document entitled How to Disclose Sponsored Travel. 43 public declarations of sponsored travel totalling $231,577.65 in calendar year 2019RecusalsMembers are prohibited under section 13 of the Code from participating in debate on or voting on a question in which they have a private interest. Section 12 requires Members who have a private interest that might be affected by a matter that is before the House of Commons or a committee to which they belong, if present during consideration of the matter, to disclose, orally or in writing, the general nature of the private interest at the first opportunity. The general nature of the private interest must be disclosed in writing to the Clerk of the House of Commons. The Clerk must ensure the disclosure is recorded in the Journals and send it to the Commissioner, who must file it with Members’ public disclosure statements. The Office communicates with Members in their preferred official language, as indicated by Elections Canada. Members may also inform the Office whether they wish to communicate in English or French. Public registry Transparency is a pillar of effective conflict of interest regimes. In this context, it means openness, clarity, unobstructed access and disclosures when interacting with, or on behalf of, the public. The conflict of interest regimes administered by the Office ensure transparency through disclosure and public declaration requirements. The Office maintains a public registry of compliance documents required under the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. It is a searchable database that contains Members' disclosure summaries and public statements relating to gifts or other benefits, sponsored travel, recusals and material changes. Public declarations made under the Code are also available for public consultation in printed form at the Office. In 2019-2020, Members declared the following: 10 material changes43 instances of sponsored travel45 gifts or other benefits164 disclosure summaries Direction and advice To help Members comply with the Conflict of Interest Code for Members of the House of Commons, the Office provides them with confidential direction and advice tailored to their individual situations. It continues to follow the processes developed since its creation and the interpretative approach taken by the Commissioner in the last two years to ensure coherence in the application of the rules set out in the Code. All Members must be able to feel confident the advice they are given is fair and appropriate. This is reflected in the Office's mission statement and is the objective of several projects in the Office's three-year strategic plan. The Office advises Members on a range of matters, both during and after the initial compliance process. The number of requests for advice decreased by 33% compared to last year. Part of this drop may be attributable to the dissolution of Parliament for the October 2019 election. During dissolution, those who were previously elected to the House of Commons are no longer Members and are therefore no longer subject to the Code. Other factors could also be at play. For example, the information the Office provides to Members through its education and outreach activities and on its website may preclude the need for them to seek advice in some cases as it may answer some of their questions. Requests for advice about the acceptability of gifts and other benefits represented 21% of the total requests for advice received by the Office in 2019-2020. Although this represents a 29% decrease compared to the 2018-2019 fiscal year, gifts remain one of the main topics that advisors are asked about. Accordingly, the subject of gifts was the focus of a joint educational activity with the Commissioner of Lobbying held in February 2020. In 2019-2020, Members asked about letters of support and fundraising: (9%)gifts or other advantages (21%)material changes (30%)general obligations (40%) Education and outreach The Office conducts a range of education and outreach activities to help Members of the House of Commons understand and meet their obligations under the Conflict of Interest Code for Members of the House of Commons. They supplement the confidential advice and direction provided to individual Members and other communications regarding compliance processes. The Commissioner has a specific mandate under section 32 of the Code to undertake educational activities for Members and the general public regarding the Code and the role of the Commissioner. Advisory opinions The Office issues, updates and disseminates various informational materials about the requirements of the Code, including advisory opinions about Members’ obligations. All informational materials are posted on the Office's website Presentations The Office offers presentations to party caucuses every year to remind Members about their obligations under the Code. In 2019-2020, seven presentations were given to MembersTotal of 289 participants Social media The Office sometimes uses Twitter (@EthicsCanada) to communicate directly with Members. For example, it tweeted reminders about deadlines for disclosing any outstanding sponsored trips so they could be included in the annual List of Sponsored Travel. In 2019-2020, the Office sent 171 tweets about its activities, role and mandate Election readiness As mentioned in last year's annual report, the Office's workload increases significantly in the lead-up to a general election and in the months that follow. As an election was scheduled for October 2019, election readiness was a key focus of its activity and planning under the Conflict of Interest Code for Members of the House of Commons in 2019-2020. Building on work begun the previous year, the Office implemented an election readiness strategy so it could best serve Members of the House of Commons in a busy election year. It covered the pre-election, election and post-election periods and contained a range of elements, all of which flowed from the Office's strategic plan. These included the hiring of additional resources to help with the increased workload. The strategy also included actions to build awareness among existing Members about their obligations under the Code and to provide educational opportunities for prospective Members. For example, updated information about the Office and the Code was provided for the House of Commons intranet site. And for the first time, the Office reached out to candidates during an election, adding a page to its website about what would be required of them under the Code if they were elected. Commissioner Dion met with the new Speaker of the House of Commons, the Honourable Anthony Rota, in January 2020. The Office also contacted the new chairs of the House of Commons Standing Committee on Procedure and House Affairs and the House of Commons Standing Committee on Access to Information, Privacy and Ethics. Furthermore, the Commissioner offered presentations to all caucuses. Two presentations to opposition parties were delivered in January and a third scheduled in the spring was postponed amid the COVID-19 pandemic. The Office gave a presentation to the Association of Parliamentary Spouses in February. In September 2019, the Chief Electoral Officer of Canada and the Conflict of Interest and Ethics Commissioner renewed their information-sharing agreement. Under it, Elections Canada transfers to the Office secure information in relation to newly elected Members following a general election or by-election. The sharing of information allows the Office, in administering the Code, to communicate in a timely manner with each newly elected Member. Enforcement While prevention is its major focus, the Office does not hesitate to apply the enforcement provisions of the Conflict of Interest Code for Members of the House of Commons as appropriate. The Conflict of Interest and Ethics Commissioner can conduct inquiries of possible contraventions of the Code, and the inquiry reports are made public. Any Member who has reasonable grounds to believe that another Member has contravened the Code may ask the Commissioner to investigate by submitting a signed, written request that identifies the alleged non-compliance and provides reasonable grounds to believe that the Code has been contravened. When the Office receives a valid request for an inquiry, it must forward it without delay to the Member named in the request and give them 30 days to respond. After receiving their response, the Office and the Commissioner conduct a preliminary review to determine if an inquiry is warranted. Within 15 working days of receiving the response, the originator of the request and the Member named in it are notified of the Commissioner's decision as to whether or not an inquiry will be conducted. Under paragraph 27(5.1)(iii) of the Code, the reasons for not proceeding with an inquiry may be described if the matter to which the inquiry relates has already been made public. The House of Commons may also direct the Commissioner, by way of resolution, to conduct an inquiry, although this has not yet occurred since the Code was adopted in 2004. The Commissioner also has the discretion to conduct an inquiry on his own initiative. The Commissioner is not empowered to impose sanctions under the Code but may recommend sanctions in inquiry reports. Section 28 of the Code provides that, following an inquiry in which the Commissioner concludes, for example, that a Member has not complied with an obligation under the Code and did not take all reasonable measures to prevent the non-compliance, or where a request for an inquiry was frivolous, vexatious or was not made in good faith, the Commissioner may recommend that the House of Commons impose appropriate sanctions. Only the House of Commons has the right to discipline its own Members and is responsible for imposing and administering sanctions, including any that may be recommended by the Commissioner. Inquiry case files When the Office receives information about a possible contravention of the Code, including through media reports or complaints from members of the public, a case file is opened. The information is reviewed to determine whether the concern raised falls within its mandate and, if it does, whether there is reason to believe that a contravention of the Code has occurred. Some of these initial reviews lead to inquiries. In other cases, an inquiry is not found to be warranted and the files are closed. How many case files were opened and closed? A case file is a concern that is reviewed by the Office. In 2019-2020, the Office reviewed 12 case files. 6 case files were closed without an inquiry4 case files are ongoing2 case files were closed with the publication of a report​ What was the source of these case files? Members of the House of Commons were the subject of these case files. The Office reviewed these 12 case files based on the following sources: the media (1)a Member of the House of Commons (5)a member of the general public (6) What was the nature of the concerns? 6 concerns were about “disclosure of information"4 concerns were about “making decisions, or seeking to influence decisions, that would further a private interest"4 concerns were about preferential treatment3 concerns were about an attempt to engage in prohibited activities Inquiries In 2019-2020, the Office issued two inquiry reports under the Conflict of Interest Code for Members of the House of Commons: In the Vandenbeld Report, issued on July 10, 2019, the Commissioner found that Ms. Anita Vandenbeld, Member of Parliament for Ottawa West–Nepean, contravened section 11 of the Code. She attempted to use her position as a Member of the House of Commons to influence the decision of voters during a 2018 municipal election so as to further the private interests of her spouse, a candidate in the election. The evidence showed that Ms. Vandenbeld used her position when she identified herself as a Member while endorsing her spouse's election bid in a letter to voters, in a recorded telephone message and when engaging in door-to-door canvassing. Noting that Ms. Vandenbeld held a sincere belief that running for public office did not engage private interests and that she immediately stopped all of her campaign activities upon seeking and obtaining his advice to do so, the Commissioner determined that her failure to comply with the Code occurred through an error in judgment made in good faith and recommended that no sanction be imposed. In the Peschisolido Report, issued on February 5, 2020, the Commissioner found that Mr. Joe Peschisolido contravened subsections 20(1) and 21(3) of the Code while he was the Member of Parliament for Steveston–Richmond East. Subsection 20(1) requires Members to fully disclose their private interests and those of their family members to the Commissioner as part of the initial compliance process after their election and during each annual review. Subsection 21(3) requires Members to notify the Commissioner of any material change to the information contained in their disclosures within 60 days after the change. Mr. Peschisolido failed to fully disclose his private interests in Peschisolido Law Corporation and changes to those private interests. He also failed to disclose a change in marital status, and to provide a full statement of his spouse's private interests. Given that Mr. Peschisolido was no longer a Member and therefore not subject to the rules governing Members of the House of Commons, the Commissioner did not issue a recommendation that the House impose appropriate sanctions, as doing so would have served no purpose. Barring exceptional circumstances, the Office's target is to conduct inquiries within a 12‑month timeframe. Public communications In 2019-2020, the Office continued to undertake a range of public communications initiatives. They are aimed at educating and informing regulatees, as well as the media and the general public, about Canada's federal conflict of interest regimes and the Office's role in administering them. The Office started developing a communications approach that identifies a range of actions in support of one of the key priorities identified in its strategic plan: building and improving communications and outreach processes. Website: 66,870 visitors In October 2019, the Office launched a new website aimed at better educating and informing regulatees, the media and the public. Designed to make information more easily accessible in the interests of transparency and accountability, it has improved functionality and is more mobile-friendly, making it a more effective source of information. Social media: 1,245 followers Twitter (@EthicsCanada) is used to communicate information about the Office and its work. Items of interest to the Office and the ethics community at large, such as relevant reports from other Canadian conflict of interest commissioners and international organizations, are retweeted. In 2019-2020, the number of followers grew by 22%, increasing the Office’s social media reach. The new communications approach includes a detailed social media plan. Media and public inquiries: 175 media and 1,608 public Recognizing the important role the media play in promoting awareness of the Commissioner’s role and man​date and the need to help them report as accurately as possible, the Office has continued to provide them with as much information as it is permitted to. It issues media advisories and news releases and shares information via Twitter in addition to responding to media and public inquiries. The Commissioner participated in six interviews with journalists in 2019-2020. Presentations: 11 presentations and 584 participants The Commissioner and representatives of the Office give a variety of presentations to help Canadians and international audiences understand the Office’s role and mandate. Where possible, participants have access to an Internet-based audience interaction tool that enables audience members to use their mobile devices to anonymously ask questions and participate in live polls. In May 2019, a senior representative of the Office gave a presentation to The Many Facets of Parliament event for parliamentary employees. In October, the Commissioner met with Parliamentary Internship Programme participants and led a discussion with political science students at the University of Ottawa. The Commissioner also gave presentations to Ontario Legislative Internship Programme students in December, and to a class at Carleton University in February 2020. That same month, he participated in the Conference Board of Canada's Public Sector Leadership Conference. The Office receives a large volume of inquiries from members of the public. When responding, it takes the opportunity to educate them about the Commissioner's role and mandate. When their concerns do not fall within the mandate of the Office, they are directed to other organizations that might be better able to assist them. The Office received 1,783 communications from the media and the public in 2019-2020. The Office strives to respond to such communications in a timely manner and has established service standards to do so. The target for achieving those service standards was set at 80%. Media requests were responded to within four hours in 86% of cases. Communications from members of the public were responded to within two weeks in 80% of cases. In 2019-2020, in support of its values of equality, respect and inclusiveness, the Office started using gender-inclusive language in its communications. Collaboration and best practices The Office continued to work with counterparts in Canada and other countries in 2019-2020, exchanging information about conflict of interest rules and practices and discussing related issues in order to stay abreast of evolving concerns and new developments in the field. Domestic outreach In September 2019, senior Office representatives attended the annual meeting of the Canadian Conflict of Interest Network (CCOIN), held in Regina, Saskatchewan. Formed in 1992, CCOIN is made up of conflict of interest commissioners at the federal level and from all Canadian provinces and territories. The Office has coordinated information gathering for CCOIN since 2010. In February 2020, the Office hosted a working meeting with the Quebec Ethics Commissioner and members of her staff. Employees in all divisions participated in briefings about Office activities and approaches in compliance, investigations, communications, strategic planning and other areas. The Office has continued to implement the March 2018 memorandum of understanding that the Commissioner signed with the Commissioner of Lobbying to cooperate on education and outreach and to jointly organize educational activities for individuals affected by the work of both offices. In February 2020, the two commissioners cohosted a teleconference for Members on gifts and other benefits, reaching 69 participants. The Commissioner meets regularly with other agents of Parliament to discuss common challenges and ways of meeting them and to listen to presentations of interest to all. Likewise, Office employees liaise with their counterparts in the offices of other agents of Parliament. For example, staff in the Communications, Outreach and Planning division attend regular meetings of an agents' communications group. Staff in the Legal Services division are part of an agents' legal services group that organized a one-day seminar in May 2019 for all lawyers in those offices. International outreach In 2019-2020, the Office remained active in the network of conflict of interest and parliamentary ethics organizations within the Organisation internationale de la Francophonie. The Réseau parlementaire, which the Commissioner helped found in 2018, seeks to foster the sharing of best practices among commissioners and other ethics and conflict of interest bodies. In October 2019, a senior Office representative attended a meeting of the group in Namur, Belgium. In December 2019, a senior Office representative made a presentation on the Commissioner's behalf at the 7th Global Conference of Parliamentarians Against Corruption. The event, organized by the Global Organization of Parliamentarians Against Corruption, took place in Doha, Qatar. In December 2019, Office representatives attended the annual conference of the Council on Governmental Ethics Laws (COGEL) in Chicago, at which a senior Office representative participated in a panel discussion about compliance communications. COGEL is a U.S.‑based, international not-for-profit organization of government ethics practitioners. The Office is a member and other Canadian conflict of interest and integrity offices are also active in it. The Office was scheduled to participate in the Organisation for Economic Co-operation and Development's Global Anti-Corruption and Integrity Forum in Paris in March 2020, but the event was cancelled because of the COVID-19 pandemic. International counterparts sometimes approach the Office to organize delegation visits. During such visits, the Office provides an overview of the Canadian ethical framework and explains the role and mandate of the Office. They are also an opportunity for the Office to learn firsthand about the ethics regimes in other countries. In December 2019, it hosted a delegation from the Ministry of Personnel Management of the Republic of Korea. Contacts with parliament The Conflict of Interest and Ethics Commissioner is an independent officer of the House of Commons who reports directly to Parliament, through the Speaker of the House of Commons, on behalf of Canadians. The Commissioner is required to submit an annual report on the administration of the Conflict of Interest Code for Members of the House of Commons to Parliament by June 30 for tabling by the Speaker of the House of Commons. The Commissioner reports on inquiries under the Code to the Speaker of the House of Commons. To further support transparency and accountability, the Office made the List of Sponsored Travel 2019 more accessible by posting the report on its website in HTML and PDF formats and as a spreadsheet. The Commissioner also testifies before parliamentary committees about the Office and its work. On May 16, 2019, he appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics about the Office's budgetary submission for the 2019‑2020 Main Estimates. The Committee has oversight responsibility for the Office and reviews its annual spending estimates. The Commissioner was prepared to respond to a request received in March 2020 from the House of Commons Standing Committee on Procedure and House Affairs to discuss the Code as part of the five-year review the Committee was undertaking, but the discussion was delayed because of the COVID‑19 pandemic. Our tools The success of the Office's mission is supported by its people and its infrastructure. Because the Office is a small organization, it also has the flexibility to respond quickly to changes in the external environment. Our people The accomplishments of the Office depend on the hard work and dedication of employees at all levels. Commissioner Dion has complete confidence in the senior management team and indeed in all Office employees. They produce work of consistently high quality, daily demonstrate rigour, professionalism and guidance on compliance matters, and act with integrity at all times. The Commissioner 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, and they ensure that all reasonable measures are provided for their safety and security. The terms and conditions of employment were updated in 2019-2020 to ensure they are in line with those of other parliamentary entities and the federal public service. The Office shares similar values with the public service and parliamentary entities. All Office employees are expected to follow the values—respect for people, professionalism, impartiality and integrity—set out in the Office's Code of Values and Standards of Conduct. These key documents were also updated in 2019-2020. The Quality Workplace Promotion Committee continued to coordinate initiatives to promote employees' well‑being. One of these was a two-day mental health first aid course offered by the Canadian Mental Health Association; participation was mandatory for directors and managers. The course was to be held twice in order to accommodate all participants, but the second session was postponed because of the COVID-19 pandemic. Our infrastructure The Office has a sound internal management framework in place to ensure the prudent stewardship of public funds, the safeguarding of public assets and the effective, efficient and economical use of resources. Because the Commissioner is an independent officer of the House of Commons and the Office is a parliamentary entity, it is not generally subject to legislation governing the administration of the public service or to Treasury Board policies and guidelines. It tries to ensure that its resource management practices are, to the greatest extent possible, consistent with those found in the public service and in Parliament. The Office also looks at policies and practices of other parliamentary entities and generally follows what they do, unless there is a valid reason to take a different approach. The Office's financial statements are audited each year by an independent external auditor. The Financial Resources Summary appended to this report outlines its financial information for the 2019‑2020 fiscal year. In March 2020, the Office organized a two-day occupational health and safety training course for its Work Place Health and Safety Committee and employees whose duties and responsibilities have an occupational health and safety component. Finally, to support efforts to limit the spread of COVID-19, in March 2020, the Commissioner suspended in-office operations and assigned all staff to telework. Thanks to measures put in place earlier and support from the House of Commons information technology group, the Office was well equipped to continue to achieve its mission under modified working conditions. Measures completed in 2019-2020 included the replacement of remaining desktop computers with laptops and tablets and the development of a pilot telework policy. The Office of the Conflict of Interest and Ethics Commissioner comprises the following divisions: Commissioner's Office (4 employees)Advisory and Compliance (19 employees)Investigations and legal services (8 employees)Communications, Outreach and Planning (8 employees)Corporate Management (11 employees) Our challenges External developments can impact the way the Office implements its mandate. All of these challenges are opportunities that carry the potential for positive change. Safeguarding the public trust Gaining and retaining public trust remains an ongoing challenge for institutions in Canada. This is evidenced by data published by credible international organizations that provide a broad indication of levels of public trust in Canada. Transparency International's Corruption Perceptions Index ranks 180 countries and territories by their perceived levels of public sector corruption. In the 2019 index, Canada ranked as the 12th least corrupt country in terms of public perception, three positions behind its 9th place ranking in 2018. The Edelman Trust Barometer is an annual survey that explores trust in business, government, non-governmental organizations and media across 28 global markets. According to its latest edition, released in February 2020, public trust in Canada slipped just below the global average in the past year. Although overall trust levels have dipped slightly, these results demonstrate that Canadians place a great deal of importance on the integrity of their institutions. Transparency and public trust interact in complex ways. In a democratic society, the latter cannot exist without the former. Yet when transparency allows light to be shined on instances of conflicts of interest, no matter how minor they might be, the public trust tends to erode. At the same time, the more issues of public integrity become salient, the better the public understands that safeguarding democratic institutions is a perpetual endeavour. It is encouraging to note that more than half of the concerns the Office reviewed in 2019-2020 came from the general public. There are advantages in harnessing public scrutiny to strengthen the Office's compliance mechanisms. After all, the public has the most to lose when the checks and balances of democracy are not respected. Hence, the Office will continue to improve its outreach and education to ensure Canadians have the tools and understanding necessary to participate in safeguarding the public trust. Effective oversight The Office can administer the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act more effectively when Members of the House of Commons and public office holders reach out to the Office before taking actions or engaging in activities that could potentially lead to a contravention of the applicable regime. Such knowledge could enable the Office to direct and advise them on how to deal with those situations in order to maintain compliance and avoid any loss of public trust. While the Office has come across information indicating potential contraventions from time to time, it has not historically conducted any active oversight. Such information also allows the Office to apply the regimes' enforcement provisions as appropriate. In 2019-2020, initial steps were taken to staff a new data analyst position in the Communications, Outreach and Planning division to help the Office improve its oversight. Monitoring of sources of public information will be conducted, particularly for positions that have been evaluated as potentially having a higher risk of conflict of interest. The need to ensure effective oversight has become even more important as a result of the COVID-19 pandemic. In such an extraordinary situation, complying with the Code and the Act may, understandably, not be top of mind for Members and public office holders. Court matters Matters involving the Office have been the object of several applications for judicial review. While dealing with them can consume a significant amount of Office resources, they can also be opportunities to clarify the Commissioner’s mandate and powers. Court matters can also be opportunities to clarify the Commissioner's mandate and powers. Democracy Watch v. Canada (Attorney General), 2020 FCA 28: The Federal Court of Appeal dismissed Democracy Watch’s appeal of a decision by the Federal Court of Canada (2018 FC 1290) in respect of the appointment of the Conflict of Interest and Ethics Commissioner. The appellant argued that the Governor in Council failed in its duty to adequately consult with leaders of the recognized parties prior to the nomination and subsequent appointment of the Commissioner, Mario Dion, in 2017. The appellant also argued that the Governor in Council was biased in its decision, since there were members of Cabinet under examination at the time of appointment. In its reasons provided from the Bench, the Court was not persuaded that the consultation process had been unreasonable and that the nature of the legislative scheme to appoint a commissioner made the appearance of bias “inevitable.” Democracy Watch has publicly stated that it intends to seek leave to appeal to the Supreme Court of Canada. Appendix Financial resources summary (thousands of dollars)Program Activity 2018-2019 Actual Spending 2019-2020 Alignment to Government of Canada Outcomes 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 5,827 6,356 6,356 6,199 Government AffairsContributions to employee benefit plans691787787687 Total spending6,5187,1437,1436,886 Plus: cost of services received without charge1,110n/an/a1,134 Net cost of department 7,6287,1437,1438,020 The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has the Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on our Office's effectiveness, management and operations, together with its operational and expenditure plans. The figures in this summary have not been audited. Complete audited financial statements will be available on our 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 Mr. Speaker: I am pleased to submit to you my 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, 2019, for tabling in the Senate. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Mario DionConflict of Interest and Ethics Commissioner Dear Mr. Speaker: I am pleased to submit to you my 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, 2019, for tabling in the House of Commons. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Mario DionConflict of Interest and Ethics Commissioner Commissioner’s message Having completed my first full fiscal year as Commissioner, I am pleased to report on the administration of the Conflict of Interest Act in 2018-2019. The regimes administered by our Office reflect what are, in my view, the four pillars common to all effective conflict of interest regimes: accountability, transparency, fairness and consistency. Accountability means being responsible and answerable for one's own actions. Transparency relates to the public disclosure of public officials' private interests and providing the public with unobstructed access to that information. Fairness requires a lack of bias on the part of the decision maker and relates to procedural fairness. Consistency means ensuring the same results when the facts are the same. With these imperatives in mind, our Office strives to continuously improve the way we administer the Act. In last year's annual report, I identified several activity areas that required special attention as they are in keeping with the aforementioned pillars. I noted, for example, the continued need to provide clear and consistent advice to public office holders and Members of the House of Commons, the potential benefits of a greater focus on education and outreach, the importance of conducting investigations in a timely manner, and the desirability of greater transparency. This report illustrates the progress that has been achieved in these areas, as well as the work that remains to be accomplished.I have also identified several other areas of focus, including election readiness. In fact, I have requested and obtained a small budgetary increase to ensure continued operational excellence going forward as we prepare for the upcoming election. I remain honoured to have been entrusted with the opportunity to administer two important components of Canada's ethical framework on behalf of Parliament and Canadians, and I would like to commend our employees for their dedicated work in 2018-2019. Mario DionConflict of Interest and Ethics Commissioner Our mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. Our stakeholders Our Office’s stakeholders include not only the individuals who are subject to the conflict of interest regimes that we administer, but also Parliament, academics, ethics practitioners and others with an interest in the field, as well as the media and the general public. While this report touches on all of our stakeholder groups, its focus is on the 2,758 public office holders who are subject to the Conflict of Interest Act. Although the population of public office holders fluctuates throughout the year, this number represents the individuals who were subject to the Act on March 31, 2019. Public office holders The Act applies to ministers, ministers of state, parliamentary secretaries, the Chief Electoral Officer, the Parliamentary Budget Officer, ministerial staff, ministerial advisers and most Governor-in-Council appointees, some ministerial appointees and any person designated to be subject to the Act by the Governor in Council. (Ministers, ministers of state and parliamentary secretaries are also subject to the Conflict of Interest Code for Members of the House of Commons.) The Act sets out a number of obligations aimed at preventing conflicts between private and public interests and prohibits various activities that could give rise to such conflicts. Types of public office holders subject to Conflict of Interest Act on March 31, 2019 Ministers and parliamentary secretaries (71 - 3%)Governor-in-Council appointees (525 - 19%)Ministerial staff (667 - 24%)Public office holders without reporting obligations (1,495 - 54%) All public office holders are subject to the Act's core set of conflict of interest and post-employment rules. "Public office holders" are subject only to those general rules. They include part-time members of federal boards, commissions and tribunals, and some part-time ministerial staff. "Reporting public office holders" are also subject to the Act's reporting and public disclosure provisions, as well as to its prohibitions against engaging in outside activities and holding controlled assets. Reporting public office holders include ministers, ministers of state, parliamentary secretaries, ministerial staff and full-time Governor-in-Council appointees such as deputy ministers, heads of Crown corporations and full-time members of federal boards. Additional rules apply to reporting public office holders who are ministers, ministers of state, parliamentary secretaries or ministerial staff. After they leave public office, public office holders are subject to the Act’s post-employment rules. Some rules have no time limits and apply to all former public office holders. Others apply only to former reporting public office holders during a one- or two-year “cooling-off” period. Types of public office holders subject to Conflict of Interest Act in previous years 2015-20162016-20172017-20182018-2019Public office holders without reporting obligations1,2901,2421,3491,495Governor-in-Council appointees476449481525Ministerial staff381497566667Ministers, ministers of state and parliamentary secretaries66666571 Appointments and departures of public office holders in 2018-2019 Newly appointed public office holdersPublic office holders who left officePublic office holders without reporting obligations385239Reporting public office holders440277 Our achievements Administering the Conflict of Interest Act requires our Office to undertake the following core activities, among others: informing public office holders about their obligations under the Act, giving them confidential direction and advice, receiving and reviewing their confidential disclosures and public declarations, maintaining a public registry of publicly declarable information, enforcing the Act as appropriate, and reporting to Parliament. The following pages explain how we undertook these core activities during fiscal year 2018‑2019. Compliance Helping public office holders achieve and maintain compliance with the Conflict of Interest Act constitutes the core work of our Office. We have ongoing contact with public office holders starting around the time of their appointment and continuing, in some cases, even after they have left public office. Accordingly, the Advisory and Compliance Division accounts for over one third of our human resources. We communicate regularly with reporting public office holders, given their reporting obligations under the Act, but we do not typically have a lot of contact with public office holders who are not reporting public office holders. We do, however, reach out to these individuals when they are first appointed or reappointed to public office, send them an annual letter reminding them of the Act's conflict of interest rules, and send them a letter summarizing the Act's post-employment rules as soon as we learn they are leaving public office. Among other activities, we provide reporting public office holders with information when they are appointed or reappointed, we help them complete their initial compliance process, we initiate their annual reviews, and we ensure that all declarable information is posted in our public registry. Although we respond to all public office holders' requests for compliance advice, we typically receive very few of such requests from those who are not reporting public office holders. In order to help them comply with the Act, we have established a service standard that requires that we contact all public office holders within three days of our Office being notified of their appointment or reappointment. In 2018‑2019, this occurred in 62% of cases. The target for achieving this service standard was set at 80%. This discrepancy is attributable to a system upgrade where numerous components required enhancements that slightly impeded service delivery. We are working diligently to address these issues to ensure service standards are met. We note, however, that first letters were sent within five business days in 90% of cases. Compliance activities for public office holders in 2018-2019 Information kits for new and reappointed public office holders: 865Initial compliance processes: 381Instances of advice provided to public office holders: 2,066Annual reminders and annual reviews: 1,913Public registry postings: 885Information on post-employment obligations: 516 Initial Compliance Process We guide reporting public office holders through the initial compliance process, which begins soon after they are appointed or reappointed to public office. Initial contact takes the form of a first letter advising them that they must submit to our Office a confidential report outlining their assets, liabilities, income, current and past activities and any other information the Commissioner considers necessary, within 60 days after their appointment. With the letter, we send newly appointed or reappointed reporting public office holders a copy of the Act and a summary of the rules that apply to them. Our Office provides assistance in completing the confidential report, as needed. Advisors review each confidential report and discuss with the reporting public office holders any measures that may be needed to ensure they are complying with the Act. Compliance measures may include the public disclosure of certain information, the divestment of controlled assets through a blind trust or arm's-length sale, the establishment of conflict of interest screens, and recusals. Our Office prepares a summary statement of each confidential report and, where applicable, a public declaration of assets, outside activities and other appropriate measures. Next, we send reporting public office holders an intermediate letter formalizing the advice and measures determined by the Commissioner that we provided to them verbally and asking them to sign these documents. They must return these signed documents within 120 days after their appointment. We then place the summary statements in our public registry. A final letter sent by the Commissioner to reporting public office holders signals the completion of the initial compliance process. Information on ongoing reporting obligations, gifts and administrative monetary penalties is enclosed. In 2018-2019, our Office established 18 compliance measures and required 55 reporting public office holders to divest their controlled assets. Ongoing Reporting Requirements Reporting public office holders also face a number of ongoing reporting requirements throughout their terms of office. Annual review: Reporting public office holders must review their disclosures with advisors from our Office every year and update information previously disclosed. Our Office sends reporting public office holders an annual review letter accompanied by copies of their summary statement and Part 2 of the Act, as well as a questionnaire. Each reporting public office holder is asked to review their information and advise us of any change. If there are changes, an advisor in our Office may contact the individual to advise if there are any measures that they must take and whether a new summary statement or declaration is required. Material changes: Reporting public office holders must inform us of any material change to any matter that they were required to disclose during the initial compliance process, within 30 days of the change. Gifts or other advantages: Reporting public office holders must publicly declare any acceptable gifts or other advantages that they or their family members accept from any one source in a 12-month period with a total value of over $200. The disclosure to our Office must be made within 30 days after the day on which the value exceeds $200. All public office holders must forfeit any gifts received as an expression of courtesy or protocol valued at $1,000 or more and the forfeiture is subject to public disclosure. Private flights: Ministers, ministers of state and parliamentary secretaries must publicly declare, within 30 days, any travel on non-commercial chartered or private aircraft accepted for themselves, their families or ministerial staff or advisers. They can only accept such travel if required in their capacity as public office holders, in exceptional circumstances or with my prior approval. Recusals: All public office holders 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. Reporting public office holders must publicly declare any recusal because of a conflict of interest within 60 days after the day on which the recusal takes place. Firm offers of outside employment: Reporting public office holders must disclose to our Office all firm offers of outside employment, within seven days after receiving them. Acceptance of offers of outside employment: Reporting public office holders must disclose to our Office and their employer the acceptance of an offer of outside employment, within seven days after accepting it. Direction and Advice Public office holders frequently seek advice from our Office, either during or after their term of office. They may consult their advisors in our Office about how to arrange their affairs to comply with the Conflict of Interest Act, how to make a public declaration, and how to deal with various situations, such as whether they may accept certain gifts or other advantages. Our Office provides tailored advice to public office holders both during and after the initial compliance process. Requests for advice relating to the acceptance of gifts represent 20% of the total requests received by our Office. This number has remained consistent in the past fiscal years. We have observed small increases in the volume of requests for advice in the period following the release of an examination report. Although we cannot ascertain that these surges are directly linked to the release of reports, we can only assume that reports serve as a reminder to public office holders of their obligation to comply with the Act. In last year’s annual report, I acknowledged the importance of ensuring that the advice our Office provides to public office holders is clear and consistent. Different public office holders who find themselves in the same situation must receive the same advice in order to reduce uncertainty and confusion and to ensure all public office holders feel confident that the advice they receive is fair and appropriate. In 2018-2019, I continued to address this challenge by engaging in ongoing dialogue with employees who provide advice to public office holders. Our Office also reviewed internal processes in order to support advisors in providing comprehensive, clear and consistent advice. Types of direction and advice given to public office holders in 2018-2019 Material changes: 659General obligations: 535Gifts or other advantages: 403Post-employment obligations: 278Outside activities: 191 Furthermore, our upgraded Integrated Case Management System, deployed in November 2018, was launched to maintain our ability to assist public office holders who contact our Office for direction and advice. (Please see Our Tools.) We recognize the importance of responding to requests for advice from public office holders in a timely manner and have established service standards to help us do so. The target for achieving those service standards was set at 80%. In 2018-2019, requests from public office holders were dealt with within three business days in 92% of cases. Instances in which public office holders sought direction and advice 2015-20162016-20172017-20182018-20191,8431,7532,0842,066 Education and outreach While I have no specific mandate under the Conflict of Interest Act to undertake educational activities as I do under the Conflict of Interest Code for Members of the House of Commons, our Office implements education and outreach initiatives on both regimes. Our Office has started following through on a commitment I made in last year's annual report to adapt our Office's outreach and communications tools to the particular characteristics and needs of the three distinct groups of public office holders—ministers, ministers of state and parliamentary secretaries, ministerial staff, including students, and Governor-in-Council appointees, each with significantly different types of work, experiences, levels of responsibility and degrees of influence—in order to ensure they are as effective as possible. This approach is reflected in the activities described below. In 2018-2019, we started moving away from a traditional "classroom" approach by developing webinars, online videos and other products using new media in order to inform and educate public office holders about their obligations under the Act. Our Office undertakes a range of education and outreach activities to help public office holders understand and meet their obligations under the Act. They are designed to supplement, not replace, the advice and direction provided to individual public office holders on a confidential basis by myself and by advisors in our Office, as well as other communications we have with them regarding the initial compliance and annual review processes. Informational materials: Our Office issues, updates and disseminates a variety of documents that provide information about the requirements of the Act, including summaries of the rules that apply to different groups of public office holders, and information notices that explain the application of various provisions. In April 2018, I launched a review of all informational materials our Office has issued under the Act to explain how the rules apply. The goal is to simplify them and reduce their number to make them a more effective source of information for public office holders to consult. In 2018-2019, we revised and updated 12 of our information notices and condensed their content into seven new notices. We are planning to update and publish the rest of the information notices in 2019-2020. The updated information notices are available on the Office website and accompanied by videos which are also available on our YouTube channel, Ethics Canada. Together these aim to offer accessible ways for public office holders to learn about and understand their obligations under the Act. One of my key roles as Commissioner is to interpret the Act. In reviewing the informational materials published by our Office for public office holders' guidance, I applied an interpretation of section 35 of the Act that represents a departure from that of my predecessor. Based on a plain reading of the Act, I am of the view that public sector entities are captured by the post-employment provision as they are an "entity." In September 2018, I informed all reporting public office holders of this change via email. It is also reflected in an updated information notice on post-employment rules. Presentations: In 2018‑2019, our Office gave 30 presentations to offices and organizations whose members are subject to the Act, reaching a total of 314 participants. I adopted a proactive approach by directly offering presentations to several organizations with large numbers of public office holders and received a positive response. While all of our presentations to public office holders in the last fiscal year were delivered in-person by myself and our employees, we now have the technological capacity to offer such presentations via webinar, allowing us to reach greater numbers of public office holders, including those who work outside of the National Capital Region, and to better accommodate their busy schedules. Correspondence: In November 2018, our Office sent an annual letter to public office holders who do not have reporting obligations to remind them of the Act's conflict of interest rules, with an emphasis on political activity in preparation for the upcoming election. Social media: We use Twitter to communicate directly with public office holders, for example by tweeting links to our updated information notices and accompanying videos. (Please also see Public Communications.) Collaboration: We started implementing the memorandum of understanding that I signed with the Commissioner of Lobbying in March 2018 to cooperate on education and outreach. Under it, we agreed to jointly organize educational activities for individuals affected by the work of both offices. Accordingly, in October 2018 I co-hosted with the Lobbying Commissioner two webinars on the subject of gifts, one in English and the other in French, reaching over 110 participants. Enforcement While prevention is my major focus, I also apply the enforcement provisions of the Conflict of Interest Act as appropriate. The enforcement function also adds to the educational role of our Office, as it has the effect of promoting awareness and understanding of the rules under the Act. There are several means of enforcing the Act. I can impose administrative monetary penalties for failures to meet certain reporting requirements. I can issue compliance orders to ensure that public office holders meet their obligations in the future. I can also initiate formal investigations, called examinations, of possible contraventions of the Act. Administrative Monetary Penalties I can issue administrative monetary penalties for failures to meet certain reporting requirements of the Act within the established deadlines, including confidential report filings, disclosures of material changes, firm offers of outside employment and their acceptance, and public declarations of gifts and recusals. Sixteen administrative monetary penalties were imposed on public office holders in 2018-2019. When a penalty is issued, the Act requires that the Commissioner make public the nature of the violation, the name of the public office holder and the amount of the penalty. This has been done to date by means of the public registry, which is accessible through our Office’s website. To enhance their deterrent effect, on April 1, 2018, we started announcing on Twitter administrative monetary penalties imposed under the Act. It is now our standard practice to announce these penalties on Twitter soon after they are added to the public registry. Number of administrative monetary penalties issued 2015-20162016-20172017-20182018-201912141616 Administrative monetary penalties issued in 2018-2019 Failure to report a material change within 30 daysIncomplete confidential reportFailure to publicly declare a gift within 30 days Compliance Orders In cases where public office holders are not meeting their obligations under the Act, I can issue compliance orders. Under section 30 of the Act, I may order a public office holder to take any compliance measure that I determine is necessary to comply with the Act. For example, I could order public office holders to submit documents for the required annual review of the information contained in their confidential report, to cease prohibited outside activities, to divest controlled assets, or to refrain from seeking to influence a decision. In 2018-2019, I issued one compliance order that required a public office holder to resign from an outside activity which conflicted with the public office holder's position. Examinations I can conduct examinations of possible contraventions of the Conflict of Interest Act. All examination reports are made public. I can launch an examination at the request of a Senator or Member of the House of Commons who provides reasonable grounds to believe the Act has been contravened. The Act also gives me the discretion to conduct an examination on my own initiative if I have reason to believe the Act has been contravened. I may base my decisions to self-initiate an examination on information that comes to the attention of our Office in various ways, including media reports and complaints from members of the public. Concerns reviewed by our Office 2015-20162016-20172017-20182018-2019Case files still under consideration at fiscal year-end21313628Case files that warranted an examination9787Case files closed without proceeding to an examination3004 Subjects of concerns raised Current or former minister or parliamentary secretary: 23Current or former public office holder: 15Person not subject to the Act: 1 Source of concerns raised Members of the general public: 30Members of the House of Commons: 4Within the Office: 4Referral from Public Sector Integrity Commissioner: 1 Nature of concerns raised Furthering a private interest: 12Preferential treatment: 8Post-employment rules: 5Duty to recuse: 4Influence: 4Gifts and other advantages: 2 When our Office receives information about a possible contravention of the Act, we open a case file. We review the information to determine whether the concern raised falls within the mandate of our Office and, if it does, whether the Member or Senator set out their reasonable grounds to believe or, in the case of a self-initiated examination, whether I have reason to believe that a contravention may have occurred. Some of these initial reviews lead to examinations. In other cases, an examination is not found to be warranted and the files are closed. In 2018-2019, our Office issued five examination reports under the Conflict of Interest Act: In the Carson Report, issued on June 7, 2018, I discontinued an examination under the Act of the post-employment conduct of Mr. Bruce Carson, a former senior advisor in Prime Minister Stephen Harper's Office. This examination had been commenced in April 2011 and was suspended in November of the same year as a result of a criminal investigation. I was only able to resume the examination in April 2018, at which time I determined that there was no need to expend further public resources by continuing an examination of a matter that had been dealt with finality by the Supreme Court of Canada and where all the relevant facts were public. In the Morneau Report, issued on June 18, 2018, I found that the Honourable Bill Morneau, Minister of Finance, did not contravene subsection 6(1) or section 21 of the Act in making decisions or having failed to recuse himself in relation to the introduction of Bill C­27, which sought to amend the Pension Benefits Standards Act, 1985. It was alleged that Mr. Morneau was in a conflict of interest when he introduced Bill C-27 because the changes to the legislation he proposed in it could further his private interests as a shareholder of Morneau Shepell Inc., a major administrator of pension plans. I needed to determine whether the interests involved were private interests within the meaning of the Act. Subsection 2(1) of the Act states that private interests do not include an interest in a decision or matter that is of general application or that affects a public office holder as one of a broad class of persons. Since the matter under examination related to all stakeholders affected by Bill C-27, I determined that it was of general application. Therefore, Mr. Morneau's interests, those of his relatives and those of Morneau Shepell Inc. were excluded from the application of the Act. In the Champan Report, issued on June 22, 2018, as a result of a referral made by the Public Sector Integrity Commissioner, I found that Ms. Marie Chapman, Chief Executive Officer of the Canadian Museum of Immigration at Pier 21, did not contravene subsection 6(1) or section 21 of the Act when she hired an alleged friend. I found that while Ms. Chapman had a friendly working relationship with the individual, they were not "friends" for the purposes of the Act. Furthermore, I found that the staffing processes were neither irregular nor unusual. Consequently, I found Ms. Chapman not to be in a conflict of interest by furthering the private interests of a friend or by improperly furthering those of another person. In the LeBlanc Report, issued on September 12, 2018, I found that the Honourable Dominic LeBlanc, when he was Minister of Fisheries, Oceans and the Canadian Coast Guard, contravened subsection 6(1) and section 21 of the Act in relation to his decision to pursue issuing an Arctic surf clam licence to the Five Nations Clam Company. The proposal submitted by the company had named Mr. LeBlanc's spouse's first cousin, a "relative" for the purposes of the Act, as General Manager should it be granted the licence. The relative stood to benefit financially if a licence was granted. When he made the decision to pursue next steps in issuing the licence to the Five Nations Clam Company, Mr. LeBlanc had read the proposal in full, and was aware of the family relationship and the relative's extensive involvement in the fishing industry. Furthermore, the relative had raised the licensing issue with Mr. LeBlanc prior to the decision. By deciding to pursue issuing the Arctic surf clam licence to the Five Nations Clam Company, Mr. LeBlanc had an opportunity to further the private interests of a relative in contravention of subsection 6(1) of the Act and failed to recuse himself as required by section 21. In the Kristmanson Report, issued on December 12, 2018, I found that Dr. Mark Kristmanson, Chief Executive Officer of the National Capital Commission (NCC), contravened subsection 11(1) of the Act on each of the 12 occasions he had accepted invitations, considered gifts for the purposes of the Act, that could reasonably be seen to have been given to influence him in the exercise of his official powers, duties and functions. Dr. Kristmanson had accepted invitations from NCC stakeholders, namely Place des Festivals, the National Arts Centre, the Canadian Museum of Nature, VIA Rail and the Royal Canadian Geographical Society, which at the time each invitation was accepted, had ongoing or foreseeable official business with the NCC. In 2018-2019, I also had two other examinations under the Act that I have yet to report on. One is related to the allegation that the Prime Minister’s Office attempted to pressure the Attorney General of Canada in relation to the SNC-Lavalin prosecution. The nature of the other examination has not been made public. Our Office is often asked for information about examinations that are in progress, but strict confidentiality requirements set out in the Act prevent us from providing any information. As noted elsewhere in this report, I issue a public report upon the completion of an examination. When I decide to discontinue an examination launched in response to a request from a Member of the House of Commons or a Senator, I issue a discontinuance report. In my last annual report, I undertook to ensure that our Office conducts examinations with due dispatch, while still conducting them thoroughly and with proper diligence and being careful to respect procedural fairness. The average length of time it took to complete the five examinations that I reported on in 2018-2019, including two that were launched by my predecessor, was 212 days, compared to an average of 336 days during our Office’s first 10 years of operation. Contacts with Parliament As an independent officer of the House of Commons, I report directly to Parliament, through the Speaker of the House of Commons. I am required to submit an annual report to Parliament by June 30 each year on the administration of the Conflict of Interest Act. I report on my examinations under the Act to the Prime Minister. I also testify before parliamentary committees about our Office and its work. In 2018-2019, I was summoned to appear before two committees: On May 1, 2018, I appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics about our Office's budgetary submission for the 2018‑2019 Main Estimates.On June 7, 2018, I appeared before the Senate Standing Committee on Legal and Constitutional Affairs during its study of Bill C-50, An Act to amend theCanada Elections Act (political financing). Possible Amendments to the Act During my appearance before the House of Commons Standing Committee on Access to Information, Privacy and Ethics on May 1, 2018, I was asked if I would be making any recommendations in my 2017-2018 annual reports to strengthen the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. I told the Committee I did not feel I had been Commissioner long enough to be able to do so in my last annual reports. I also expressed my hope that the Committee would invite me to present my thoughts on possible amendments in fall 2018, and that I would include something in my 2018-2019 annual reports. My recommendations regarding possible amendments to the Act are described in broad terms below. While there is room for improvement with regard to clarifying the rules and their application, I wish to emphasize that I believe the Act allows our Office to properly fulfil its mandate in the immediate term. Several of my recommendations seek to strengthen the Act's consistency and fairness, by simplifying and standardizing its provisions dealing with gifts and other advantages, improving its categorization of public office holders, strengthening post-employment reporting requirements, as well as strengthening the provisions regarding reporting obligations of public office holders. My other recommendations seek to improve our Office's efficiency and transparency by instituting mandatory training requirements for public office holders, improving investigation processes and establishing deadlines for annual reviews. Public communications In last year's annual report, I identified an increase in the number of communications from members of the public and requests for information or interviews from the media as significant trends. Those numbers remained at relatively high levels in 2018-2019. Our Office undertakes a range of initiatives aimed at educating and informing our stakeholders, including ethics practitioners, academics and others with an interest in the field, as well as the media and the general public, about Canada's federal conflict of interest regimes and the role of our Office in administering them. Website: We make a wide range of information available on our Office website, which we update on an ongoing basis. In late 2018-2019, we started work on the development of a new website that will be launched in advance of the October 2019 federal election. Social media: We have used Twitter to communicate more information about our Office and its activities and to retweet items of interest to our Office and the ethics community at large, such as relevant reports from other Canadian conflict of interest commissioners and international organizations. We currently have two Twitter accounts, one for each official language. Counting the number of followers for both accounts, we have more than doubled our number of Twitter followers (1,023 on March 31, 2019), surpassing the goal of 1,000 that I set for the end of 2018-2019 and increasing our Office's social media reach. Presentations: Giving presentations to various organizations and at various events contributes to public awareness of Canada's federal conflict of interest regimes and increases public understanding of the Commissioner's role and mandate. In November 2018, I delivered the Annual Public Policy Lecture at York University's McLaughlin College. I shared my perspective on the development of ethics regimes governing the conduct of federal officials in Canada and discussed the relevance of conflict of interest regimes to the broader field of ethics and to politics and democracy. Also in November 2018, I gave two presentations to political science students at the University of Ottawa, and a senior representative of our Office did so in March 2019. At the March event, we started using an Internet-based audience interaction tool that enables audience members to use their mobile devices to ask questions and participate in live polls. Media and public inquiries: Cognizant of the important role the media play in promoting awareness of the mandate and activities of our Office, I have undertaken to ensure we provide them with as much information as the regimes that I administer allow. In our dealings with the media, we always take the opportunity to inform and educate them about my role and mandate and the functioning of the Act and the Code, in order to help them report accurately about our Office. We issue media advisories and news releases about our work, such as the issuance of public reports, and publicize other information, such as the imposition of administrative monetary penalties and compliance orders via Twitter. I participated in 14 interviews with journalists in 2018-2019. We also receive a large volume of inquiries from members of the public. Similarly, when we respond, we take the time to educate them about our role and mandate and, when their concerns do not fall within our mandate, try to direct them to other organizations that might be better able to assist them. Our Office received 2,499 communications from the media and the public in 2018-2019. This represents a 19% decrease compared to last fiscal year. This may be due to the fact that our Office as a whole received less attention on Twitter, in the news and during Question Period compared to the previous year. We recognize the importance of responding to communications from members of the public and the media in a timely manner and have established service standards to help us do so. The target for achieving those service standards was set at 80%. Media requests were responded to within three hours in 86% of cases. Communications from members of the public were responded to within two business days in 81% of cases. Because of high volumes and in order to maintain the high quality of our responses, we are looking at revising our service standards. Requests for information and interviews from media 2015-20162016-20172017-20182018-2019143315411260 Communications from the public 2015-20162016-20172017-20182018-20191,3732,0662,6622,239 Collaboration and best practices Our Office acts as an information resource for other jurisdictions and organizations, both domestic and international, by meeting with visiting delegations, responding to information requests and participating in conferences related to conflict of interest and ethics. Our Office continued to work with counterparts in Canada and other countries in 2018-2019, exchanging information about conflict of interest rules and practices and discussing related issues in order to stay abreast of concerns and developments in the field. Domestic Outreach In May 2018, our Office participated in the Public Sector Ethics Conference in Toronto, where I took part in a panel discussion on financial disclosure. In September 2018, several representatives of the Office and I attended the annual meeting of the Canadian Conflict of Interest Network (CCOIN), held in St. John’s, Newfoundland and Labrador. Created in 1992, CCOIN is made up of conflict of interest commissioners at the federal level and from all Canadian provinces and territories. Our Office has coordinated information-gathering for CCOIN since 2010. International Outreach Achieving a culture of ethics and integrity is a keystone of good governance. It is also necessary for the effective functioning of democracies. Individuals who hold public office, whether elected or appointed, are expected to always act in the public interest. Their decisions must never be guided by their private interests or those of their friends, families or relatives. A legal framework setting out rules governing conduct helps to ensure the decisions of those who hold public office are made in the public interest. Because these expectations are clearly embedded in the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons, many other countries look to Canada as a model for the development of their own conflict of interest regimes. In July 2018, I helped found a new network of conflict of interest and parliamentary ethics organizations within the Organisation internationale de la Francophonie. The Réseau parlementaire will foster the sharing of best practices among commissioners and other ethics and conflict of interest bodies. The goal is to enhance expertise among the parliaments of Francophonie member countries in order to adopt ethics principles and conflict of interest rules. In October 2018, a senior representative of our Office made a presentation on my behalf at the High-Level Conference on "Strengthening Transparency and Accountability to Ensure Integrity: United Against Corruption." The event, which took place in Croatia, was organized jointly by the Group of States Against Corruption (GRECO) and the Croatian government. GRECO is the Council of Europe's anti-corruption monitoring body. In December 2018, several representatives of our Office attended the annual conference of the Council on Governmental Ethics Laws (COGEL), in Philadelphia. COGEL is a U.S.‑based, international not-for-profit organization of government ethics practitioners of which our Office is a member. A number of Canadian conflict of interest and integrity offices were represented as well, and a senior representative of our Office participated in a panel discussion about reporting obligations. In March 2019, our Office was represented at the Global Anti-Corruption and Integrity Forum hosted in Paris by the Organisation for Economic Co-operation and Development (OECD). In 2018-2019, a number of our international counterparts approached our Office to organise delegation visits. During such visits, we provide a brief overview of the Canadian ethical framework, as well as the role and mandate of our Office. It is also an opportunity for our Office to learn firsthand about the ethics regimes in other countries. In November 2018, we hosted incoming delegations from the Haute Autorité de la Bonne Gouvernance of the Ivory Coast, and the Anti-Corruption and Civil Rights Commission of South Korea. Transparency I believe Canadians should receive as much information as possible about the work of our Office. In last year's annual report, I committed to making our Office and its work as transparent as possible, while respecting the strict confidentiality requirements set out in the Conflict of Interest Act, particularly regarding examinations and advice provided to public office holders. There may also be other valid reasons in some cases for not divulging information even when we are permitted to do so. For example, I have chosen to not identify the subjects of ongoing examinations at this time in order to safeguard their privacy against the possibility of undue reputational damage. If those examinations proceed, we will report publicly on the findings upon their completion. While respecting these constraints and other considerations, we will be as forthcoming with Parliament, the media and the public as we are permitted to be under the Act. In support of that commitment, in 2018-2019 we began releasing quarterly statistical reports. The purpose is to align our activities with our mission, assess our workload and identify current trends. The quarterly statistical report contains data on various activity areas, including the provision of direction and advice to public office holders and Members of the House of Commons, education and outreach, and enforcement. It also includes figures on how our Office meets its service standards. We also use the data internally to gauge our workload and performance, and to measure progress towards the objectives set out in our Office's strategic plan (please see Our Plan). The data also contributes to strategic decision making. Our quarterly statistical report is released on the last business day of the month following the end of the quarter for which the data is compiled. The aggregated data for 2018-2019 is published in this report and in the annual report under the Conflict of Interest Code for Members of the House of Commons. Our tools The success of our Office’s mission is supported by the strength of our people, our plan and our infrastructure. Our people I recognize that any accomplishments I may have as Commissioner depend on the hard work and dedication of our employees at all levels within the organization. Accordingly, I have taken steps to ensure our Office invests in employees’ training and professional development and provides the tools and equipment they need to perform their jobs effectively and safely. I have also acted to ensure it offers a respectful, diverse and inclusive workplace and am mindful of the importance of an appropriate work-life balance. The Quality Workplace Promotion Committee, which I established early in my tenure as Commissioner to promote employees’ well‑being, is playing a key role in some of these important areas. One of the initiatives introduced through the Committee is the implementation in our Office of the Canadian Mental Health Association’s Not Myself Today program. It focuses on building greater awareness and understanding of mental health, reducing stigma, and fostering safe and supportive work cultures. Our plan A rolling three-year strategic plan, which is published on the Office website, helps guide our projects and activities in support of our mission. It identifies three key priorities and the means by which we will achieve them. In 2018-2019, we completed a number of specific projects and activities, identified elsewhere in this report, that contributed directly to the following priorities: Build and improve communications and outreach processesModernize technology and information management structuresMaintain operational excellence Our strategic plan is an evergreen tool that is meant to capture the Commissioner's vision. In January 2019, one year after I started my mandate as Commissioner, we conducted a strategic plan refresh exercise to pinpoint projects to be undertaken in the next fiscal year. Those discussions led to a small shift in our priorities, which were identified as follows: Build and improve communications and outreach processesImprove the Office's mechanisms for conflict of interest preventionMaintain operational excellence (tools and people) These priorities will be supported by specific projects and activities that we have identified. Progress against our strategic plan will continue to be monitored on an ongoing basis and I will report on it in future annual reports to Parliament. Our infrastructure We have a sound internal management framework in place to ensure the prudent stewardship of public funds, the safeguarding of public assets and the effective, efficient and economical use of resources. Because I am an independent officer of the House of Commons and our Office is a parliamentary entity, we are not generally subject to legislation governing the administration of the public service or to Treasury Board policies and guidelines. We try to ensure that our resource management practices are, to the greatest extent possible, consistent with those found in the public service and in Parliament. We also look at various policies and practices of other parliamentary entities and generally follow what they do, unless there is a valid reason for our Office to take a different approach. Our Office’s financial statements are audited each year by an independent external auditor and no concerns have been raised. A Financial Resources Summary appended to this report outlines our financial information for the 2018‑2019 fiscal year. In November 2018, we launched an upgraded Integrated Case Management System. All information from our old system was migrated to the new one, supported by the House of Commons’ information technology group. Several customizations that had been made previously were replaced with more streamlined solutions so operations were not interrupted. Our upgraded information technology infrastructure is compatible with existing systems and allows our Office to explore new technology options for delivering our mandate. Because of the scope of this transition, we are still dealing with technical and procedural issues that we are working to resolve. Distribution of positions within our Office Commissioner's Office (4) Advisory and Compliance (18) Investigations and Legal Services (8) Communications, Outreach and Planning (8) Corporate Management (11) Our challenges The way I implement my mandate as Commissioner can be impacted by developments in the external environment. Some of those may be viewed as challenges and others as opportunities. In my view, however, they all represent the potential for positive change. Safeguarding the public interest One of the purposes of the Conflict of Interest Act is to "minimize the possibility of conflicts arising between the private interests and public duties of public office holders and provide for the resolution of those conflicts in the public interest should they arise." By helping public office holders avoid and prevent conflicts between private and public interests, I believe our Office plays an important role in maintaining the integrity of public officials and the public institutions in which they serve. I believe that respect of the reporting deadlines set out in the Act are an indicator of how effectively we are fulfilling that role. Our data illustrates that most reporting public office holders meet the deadlines set out in the Act. In some cases, deadlines are missed because of delays in notifying our Office of appointments, or because of other circumstances beyond the reporting public office holders' control. As shown in graph 15, a large majority of reporting public office holders have historically respected the deadlines imposed by the Act. I also believe that increased communications with our Office are another indicator of compliance. I have been interested in determining the average number of times that a public office holder contacts our Office to request advice, or to make updates to their files. Percentage of new or reappointed reporting public office holders who have filed within one week of the deadlines imposed by the Act 2009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-20182018-201989%91%97%91%94%93%96%80%92%96% One can assume that this voluntary compliance on the part of public office holders is a step in the right direction for safeguarding the public interest. We have determined that, on average, public office holders request advice twice per year. Leveraging new technology Just as we have made use of new technologies to increase the reach of our education and outreach activities and their ease of access, I believe there are opportunities to leverage new technologies so our Office can better assist public office holders in identifying potential conflicts of interest in order to prevent them from developing. For example, I believe artificial intelligence could have great potential in the development of an electronic oversight tool. It is not beyond the realm of possibility that one day we could have a system that contains data not only on public office holders, such as their assets and liabilities, but also on the official decisions they are making or have made. The system would be able to automatically generate red flags that would alert individual public office holders as well as the Commissioner, making it possible to avoid conflicts of interest or to address them right away. We are, of course, a long way from achieving such a system, and there are issues that would have to be addressed, such as how to obtain and input data on decisions, as well as privacy considerations. In October 2015, our Office launched a secure declaration portal to facilitate the process by which public office holders meet their reporting requirements. The portal usage is high (74% of declarations are approved or submitted through the portal). As the portal has become a popular tool, our Office is considering ways to increase its potential in order to improve efficiency. Harnessing the use of technology to improve compliance is a trend that is being seen on a global level. Our Office was represented at the Organisation for Economic Co‑operation and Development’s 2019 Integrity Forum, whose theme was “Technology for Trust.” The Forum explored the many ways technology is being used by governments and organizations to implement and improve their ethics frameworks. As well, an Office employee recently attended seminars focusing on artificial intelligence and business analytics in order to help us to start incorporating technology in more of our internal processes. Election readiness With a federal election scheduled to take place in October 2019, our Office's workload is expected to increase significantly. General elections always occasion a high level of turnover among ministers, ministers of state, parliamentary secretaries, ministerial staff and ministerial advisers, all of whom are subject to the Conflict of Interest Act as reporting public office holders. In fact, parliamentary secretaries cease being reporting public office holders under the Act once the writ is dropped and become subject only to the Act's post-employment provisions. (Ministers, ministers of state and ministerial staff remain subject to the Act as reporting public office holders during the election period.) In addition to assisting those leaving public office with their post-employment obligations under the Act, we will have to guide newly appointed ministers, ministers of state, parliamentary secretaries, ministerial staff and ministerial advisers through the initial compliance process. We started preparing for the election in 2018‑2019. For example, we worked on processes for the hiring of employees and students to help with the increased workload. We updated letters and documents, and improved our fillable electronic forms to make it easier for reporting public office holders to complete their confidential report. We also offered presentations about the Act’s post-employment rules. Court matters Matters involving our Office have been the object of several applications for judicial review. While dealing with them can consume a significant amount of Office resources, I believe they can also be opportunities to clarify the Commissioner's mandate and powers. On October 26, 2018, the Federal Court of Appeal rendered two separate unanimous judgments dismissing applications for judicial review filed by the advocacy group Democracy Watch that were challenging "decisions" taken by the former Commissioner. In Democracy Watch v. Attorney General of Canada, 2018 FCA 195, the Court dismissed Democracy Watch's application for judicial review because of mootness. Democracy Watch was challenging the former Commissioner's letter to the Honourable Bill Morneau on the basis that it was a refusal by the former Commissioner to exercise her jurisdiction. In that letter, Mr. Morneau was informed that he was not required to divest his shares of private holding corporations which held publicly traded shares of a family company. The Court considered that Mr. Morneau had stated in the House of Commons in November 2017 that he had sold all the shares in his family company, which rendered the application moot. In Democracy Watch v. Attorney General of Canada et al., 2018 FCA 194, the Court dismissed Democracy Watch's application for judicial review challenging the Commissioner's authority to determine whether a conflict of interest screen was an appropriate compliance measure under section 29 of the Conflict of Interest Act as it applied to the Honourable Dominic LeBlanc. Our Office was granted intervener status by the Court. The Court concluded that screens are a reasonable exercise of the Commissioner's authority and that the former Commissioner's interpretation and application of her home statute, the basis for screens, was reasonable. In arriving at its decision, the Court considered the broad language of the Commissioner's discretionary powers under section 29 of the Act, and determined that screens, meant to prevent conflicts of interest, are a measure entirely compatible with the intent and spirit of the Act. Democracy Watch sought leave to appeal this decision to the Supreme Court of Canada, which dismissed the application on May 2, 2019. On December 19, 2018, the Federal Court, in Democracy Watch v. Attorney General of Canada, 2018 FC 1290, rendered a judgment dismissing an application for judicial review filed by Democracy Watch challenging the appointment of Mr. Mario Dion as Conflict of Interest and Ethics Commissioner. This decision is presently being appealed by the applicant. Appendices Financial resources summary ​(thousands of dollars)​​Program Activity ​2017-2018 Actual Spending 2019-2020 ​Alignment toGovernment of CanadaOutcomes​ ​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​​ ​ 5,973 ​ 6,134 ​ 6,134 ​ 5,827 ​Government Affairs​Contributi​ons to employee benefit plans665734734691​​Total spending6,6386,8686,8686,518​​Plus: cost of services received without charge​1,148​n/a​n/a​1,110​ Net cost of department ​7,7866,8686,8687,628​​​​ The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has his Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on our Office’s effectiveness, management and operations, together with its operational and expenditure plans. Complete audited financial statements can be found on our website. Our history 1973 Prime Minister Pierre Elliott Trudeau introduced conflict of interest guidelines for cabinet ministers; guidelines for various groups of public servants and Governor-in-Council appointees were announced 1974 Prime Minister Pierre Elliott Trudeau appointed David Taylor as Canada’s first federal conflict of interest administrator, an Assistant Deputy Registrar General; office established within former Department of Consumer and Corporate Affairs 1985Prime Minister Brian Mulroney issued Conflict of Interest and Post-Employment Code for Public Office Holders, consolidating in one document the rules for ministers, parliamentary secretaries, ministerial staff and Governor-in-Council appointees1994 Prime Minister Jean Chrétien appointed Howard Wilson to new position of Ethics Counsellor, which replaced Assistant Deputy Registrar General; Ethics Counsellor reported to Prime Minister 2004 An Ethics Commissioner, created as a separate parliamentary entity, replaced the position of Ethics Counsellor; Bernard Shapiro appointed to the position; Conflict of Interest Code for Members of the House of Commons adopted 2006 Prime Minister Stephen Harper introduced Conflict of Interest Act as part of Federal Accountability Act, replaced Conflict of Interest and Post-Employment Code for Public Office Holders; position of Conflict of Interest and Ethics Commissioner was created 2007 Conflict of Interest Act came into effect; Mary Dawson appointed first Conflict of Interest and Ethics Commissioner 2017Mario Dion was appointed second Conflict of Interest and Ethics Commissioner The Office of the Conflict of Interest and Ethics Commissioner was created in July 2007 when the Conflict of Interest Act, passed in 2006 as part of the Federal Accountability Act, came into effect. It is important to understand, however, that significant milestones had already been achieved in the preceding decades.

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 my 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, 2019, for tabling in the House of Commons. This fulfills my obligations under paragraph 90(1)(a) of the Parliament of Canada Act. Sincerely, Mario DionConflict of Interest and Ethics Commissioner Commissioner's message Having completed my first full fiscal year as Commissioner, I am pleased to report on the administration of the Conflict of Interest Code for Members of the House of Commons in 2018‑2019. The regimes administered by our Office reflect what are, in my view, the four pillars common to all effective conflict of interest regimes: accountability, transparency, fairness and consistency. Accountability means being responsible and answerable for one's own actions. Transparency relates to the public disclosure of public officials' private interests and providing the public with unobstructed access to that information. Fairness requires lack of bias on the part of the decision-maker and relates to procedural fairness. Consistency means ensuring the same results when the facts are the same. With these imperatives in mind, our Office strives to continuously improve the way we administer the Code. In last year's annual report, I identified several activity areas that required special attention as they are in keeping with the aforementioned pillars. I noted, for example, the continued need to provide clear and consistent advice to Members of the House of Commons and public office holders, the potential benefits of a greater focus on education and outreach, the importance of conducting investigations in a timely manner, and the desirability of greater transparency. This report illustrates the progress that has been achieved in these areas, as well as the work that remains to be accomplished. I have also identified several other areas of focus, including election readiness. In fact, I have requested and obtained a small budgetary increase to ensure continued operational excellence going forward as we prepare for the upcoming election. I remain honoured to have been entrusted with the opportunity to administer two important components of Canada's ethical framework on behalf of Parliament and Canadians, and I would like to commend our employees for their dedicated work in 2018-2019. Mario DionConflict of Interest and Ethics Commissioner Our mission Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. Our stakeholders Our Office's stakeholders include not only the individuals who are subject to the conflict of interest regimes that we administer, but also Parliament, academics, ethics practitioners and others with an interest in the field, as well as the media and the general public. While this report touches on all of our stakeholder groups, its focus is on the 338 elected Members of Parliament who are subject to the Conflict of Interest Code for Members of the House of Commons. The Code sets out a number of obligations aimed at preventing conflicts between private and public interests and prohibits various actions that could give rise to such conflicts. Members who are ministers, ministers of state or parliamentary secretaries are also subject to the Conflict of Interest Act, which imposes additional reporting obligations and compliance measures on them, as reporting public office holders. Members of the House of Commons on March 31, 2019 Members of the House of Commons (264)Parliamentary secretaries (36)Ministers (35) Note: Three seats were vacant on March 31, 2019 Our achievements Administering the Conflict of Interest Code for Members of the House of Commons requires our Office to undertake the following core activities, among others: informing Members about their obligations under the Code, giving them confidential direction and advice, receiving and reviewing their confidential disclosures and public declarations, maintaining a public registry of publicly declarable information, enforcing the Code as appropriate, and reporting to Parliament. The following pages explain how we undertook these core activities during fiscal year 2018‑2019. Compliance Helping Members achieve and maintain compliance with the Conflict of Interest Code for Members of the House of Commons constitutes the core work of our Office. We have ongoing contact with Members from the time notice of their election is published in the Canada Gazette until they leave public office. Accordingly, the Advisory and Compliance Division accounts for over one third of our human resources. Our Office works with Members from the time they are elected to help them achieve compliance with the Code's initial reporting requirements and to maintain compliance with the Code throughout their terms in office. Among other activities, we provide Members with information when they are elected, we help them complete their initial compliance process, we send them reminders about their annual reviews, and we ensure that all declarable information is posted in our public registry. We also respond to all Members' requests for compliance advice. As a result of the five by-elections in 2018-2019, we distributed five information kits to newly elected Members. We completed four initial compliance processes, two of which resulted from by-elections in the previous reporting period. Compliance activities completed for Members of the House of Commons in 2018-2019 Instances of advice provided to Members (700)Annual reviews (158)Public registry postings (368) Initial Compliance Process The first step for Members to achieve compliance consists of preparing a confidential disclosure statement of detailed information on assets, liabilities, outside activities and other interests for themselves and their immediate family members. Each Member must submit a disclosure statement with supporting documents, such as financial statements, to our Office no later than 60 days after notice of the Member's election is published in the Canada Gazette. Advisors in our Office review the information in the disclosure statements and advise Members on achieving and maintaining compliance with the Code. We might also request further information to clarify or confirm the information provided, and may also recommend specific compliance measures to prevent conflicts of interest. Once all of the required information has been obtained, we prepare a disclosure summary. Members have 60 days to review and sign their disclosure summaries, which are then placed in the public registry maintained by our Office. Our Office maintains a Members' Compliance S​tatus Report that identifies where each Member is in the initial compliance process on a specific day. This report is available and is updated as required, and more frequently after general elections. Ongoing reporting requirements Members also face a number of ongoing reporting requirements throughout their terms of office. Annual review: Members must review their disclosures with advisors from our Office every year and update information previously disclosed to our Office. The current annual review process involves reviewing a summary of information and answering a questionnaire. If any changes are submitted, an advisor in our Office may contact the Member to advise if any additional compliance measures must be taken and whether an amendment to the Member's disclosure summary is required. I have reviewed the rules of the Code and have determined that the current annual review process is not fully reflective of Members' obligations. However, I have not yet instituted any changes as I did not wish to modify the process before the general election scheduled to be held in October 2019. Our Office will continue to follow the current process until then. After the election and in accordance with paragraph 20(1)(ii) of the Code, each Member will be required to file a full disclosure statement 60 days after the date established by the Commissioner for the Member's annual review. Material changes: Members must inform us of any material change to the information contained in their disclosure statement, within 60 days after the change. This also allows our Office to advise if there are any measures that must be taken and whether an amendment to the disclosure summary is necessary. Gifts or other benefits: Members must publicly declare any acceptable gifts or other benefits related to their position that have a value of $200 or more, within 60 days after acceptance. Sponsored travel: The Code allows Members to accept sponsored travel that arises from or relates to their position. In cases where the costs covered by the sponsor exceed $200, Members must disclose the sponsored travel within 60 days after the end of the trip. Public declarations of sponsored travel by Members are posted in the public registry maintained by our Office. Each year, we produce a list of sponsored travel for the previous calendar year that I must submit to the Speaker of the House of Commons by March 31 for tabling in the House. The List of Sponsored Travel 2018 is available on our website. Recusals: Members are prohibited under section 13 of the Code from participating in debate on or voting on a question in which they have a private interest. Section 12 of the Code requires a Member who has a private interest that might be affected by a matter that is before the House of Commons or a committee to which they belong, if present during consideration of the matter, to disclose, orally or in writing, the general nature of the private interest at the first opportunity. The general nature of the private interest must be disclosed in writing to the Clerk of the House of Commons. The Clerk must ensure the disclosure is recorded in the Journals and send the disclosure to the Commissioner, who must file it with Members' public disclosure statements. As required by the Code and in the interest of transparency, ongoing reporting requirements are posted in the public registry. Graph 3 provides a visual representation of the volume of public declarations made during the year. Public declarations made by Members of the House of Commons Disclosure summaries (147)Gifts or other benefits (100)Sponsored travel (81)Material changes (40) Direction and advice Members of the House of Commons frequently seek advice from our Office. They may consult their advisors in our Office about how to arrange their affairs to comply with the Conflict of Interest Code for Members of the House of Commons, how to make a public declaration, and how to deal with various situations, such as whether they may accept certain gifts or other benefits. Our Office provides tailored advice to Members both during and after the initial compliance process. In last year's annual report, I identified a growing number of requests for advice from Members as a significant trend. While the number of requests for advice remained high in 2018-2019, we noted some fluctuations around the nature of the requests. Types of direction and advice given to Members of the House of Commons in 2018-2019 Material changes (237)General obligations (210)Gifts or other benefits (204)Letters of support and fundraising (49) Requests for advice relating to the acceptability of gifts represented 29% of the total requests for advice received by our Office in 2018-2019. This number is slightly higher than in past fiscal years; the average since 2010 was 22%. This may be attributable, in part, to our October 2018 release of an advisory opinion called Gifts or other benefits to Members—Services of interns provided free of charge. In last year's annual report, I acknowledged the importance of ensuring the advice our Office provides to Members is clear and consistent. Different Members who find themselves in the same situation must receive the same advice in order to reduce uncertainty and confusion and to ensure all Members feel confident the advice they receive is fair and appropriate. In 2018-2019, I continued to address this challenge by engaging in ongoing dialogue with employees who provide advice to Members. Our Office also reviewed internal processes in order to support advisors in providing comprehensive, clear and consistent advice. Furthermore, our updated Integrated Case Management System, deployed in November 2018, was launched to maintain our ability to assist Members who contact our Office for direction and advice. We recognize the importance of responding to requests for advice from Members in a timely manner and have established service standards to help us do so. The target for achieving those service standards was set at 80%. In 2018-2019, requests from Members and public office holders were dealt with within three business days in 92% of cases. Instances in which Members of the House of Commons sought direction and advice 2015-20162016-20172017-20182018-2019409628814700 Education and outreach While our Office conducts education and outreach on both of the conflict of interest regimes that I administer, I have a specific mandate under section 32 the Conflict of Interest Code for Members of the House of Commons to undertake educational activities for Members and the general public regarding the Code and the role of the Commissioner. Our Office undertakes a range of education and outreach activities to help Members understand and meet their obligations under the Code. They are designed to supplement, not replace, the advice and direction provided to individual Members on a confidential basis by myself and by advisors in our Office, as well as other communications we have with them regarding the initial compliance and annual review processes. In 2018-2019, we started developing webinars, online videos and other products using new media in order to inform and educate Members about their obligations under the Code. We have also started the development of a new mobile-friendly website with implementation planned in advance of the October 2019 general election. Informational materials: We issue, update and disseminate various informational materials about the requirements of the Code, including backgrounders and advisory opinions about Members' obligations, which are posted on our website. In April 2018, I launched a review of all informational materials our Office has issued under the Conflict of Interest Code for Members of the House of Commons to explain how the rules apply. The goal is to make them a more effective source of information for Members to consult. The new suite of materials will be released in October 2019 following the general election. In May 2018, I issued an advisory opinion about the acceptability under the Code of barbecue services provided free of charge by a corporation for community events hosted by Members in their ridings. I advised Members that I am of the view that those services are benefits as defined in the Code, which include services or the use of property provided without charge or at less than their commercial value. These services are therefore subject to the acceptability test set out in subsection 14(1) of the Code. It prohibits Members and their family members from accepting, directly or indirectly, any gift or other benefit that might reasonably be seen given to influence the Members in the exercise of a duty or function of their office. Since the company offering the free services is registered to lobby the House of Commons and is frequently engaged in doing so, I am of the opinion that even if a particular Member has not personally been lobbied by the company, this benefit would not pass the Code's acceptability test, as it could reasonably be seen to have been given to influence the Member in the exercise of their official duties. In fact, the importance of education and outreach in minimizing conflicts of interest is illustrated by a matter that was brought to my attention in September 2018. For years, third-party organizations have been providing Members with interns to work in their offices, at no cost to the Members. Such arrangements not only benefit the Members by providing them with free labour, but also benefit the interns by giving them parliamentary experience, and they could even benefit the sponsoring organizations, some of which are registered to lobby the House of Commons. In short, Members who accept free intern services could be in a conflict of interest vis-à-vis the sponsoring organization. To prevent such a situation from developing, I issued an advisory opinion in October 2018 under subsection 26(4) of the Code. In it, I noted that even though the interns are not paid by Members, they are not volunteers, because they are paid by the organization that placed them. I am of the view that any intern services provided to Members free of charge by a third party are benefits as defined in the Code and are therefore subject to the acceptability test set out in subsection 14(1). When the organization offering the intern services is registered to lobby the House of Commons—even if it has not lobbied the Member in question—the Code does not allow the Member to accept a gift or other benefit from that organization as it might reasonably be seen to have been given to influence the Member in the exercise of a duty or function of their office. The same applies if the Member has or may have official dealings with the organization, now or in the future. Furthermore, even where accepting intern services provided at no cost is allowed, these services are subject to the requirement to report the benefit within 60 days after the start of the internship, as prescribed in subsection 14(3) of the Code. Presentations: We offer presentations to party caucuses and independents every year in order to remind Members about their obligations under the Code. This year, a presentation was offered to inform Members of their obligations leading up to an election period. Social media: We have used Twitter to communicate directly with Members. For example, we tweeted reminders about deadlines for disclosing to our Office any outstanding sponsored trips in preparation for the annual publication of the list of sponsored travel. Collaboration: We started implementing the memorandum of understanding that I signed with the Commissioner of Lobbying in March 2018 to cooperate on education and outreach. Under it, we agreed to jointly organize educational activities for individuals affected by the work of both offices. Accordingly, in October 2018 I co-hosted with the Lobbying Commissioner two webinars on the subject of gifts, one in English and the other in French, reaching over 110 participants. Enforcement While prevention is my major focus, I also apply the enforcement provisions of the Conflict of Interest Code for Members of the House of Commons as appropriate. The enforcement function also adds to the educational role of our Office, as it has the effect of promoting awareness and understanding of the rules under the Code. I can conduct inquiries of possible contraventions of the Code, and my inquiry reports are made public. Any Member who has reasonable grounds to believe that another Member has contravened the Code may ask me to investigate by submitting a signed, written request that identifies the alleged non-compliance and provides reasonable grounds to believe that the Code has been contravened. When I receive a valid request for an inquiry, I must forward the request without delay to the Member named in it and give the Member 30 days to respond. After receiving the Member's response, our Office conducts a preliminary review to determine if an inquiry is warranted. Within 15 working days of receiving the Member's response, we notify the originator of the request and the Member named in it whether or not an inquiry will be conducted. Under paragraph 27(5.1)(iii) of the Code, I may describe the reasons for not proceeding with an inquiry where the matter to which the inquiry relates has already been made public. The House of Commons may also direct me, by way of resolution, to conduct an inquiry, although this has not yet occurred in the 15 years since the Code was adopted. I also have the discretion to conduct an inquiry on my own initiative. From time to time, our Office receives information about possible contraventions of the Code, including through media reports or complaints from members of the public. In each instance, we review the information to determine whether the concern raised falls within the mandate of our Office and whether there is reason to believe that a contravention of the Code has occurred. Some of these preliminary reviews lead to inquiries; in other cases, an inquiry is not found to be warranted and the case file is closed. Case files reviewed by our Office 2015-20162016-20172017-20182018-2019Case files still under consideration at fiscal year-end0032Case files that warranted an inquiry0116Case files closed without proceeding to an inquiry36721 Source of concerns raised Members of the general public (10)Members of the House of Commons (10)Within the Office (9) Nature of concerns raised Gifts or other benefits (8)Making decisions, or seeking to influence decisions, that would further a private interest (7)Disclosure of information (7)Outside activities (1) Note: Only the main concerns are represented. I am not empowered to impose sanctions under the Code. I may, however, recommend sanctions in my inquiry reports. Section 28 of the Code provides that, following an inquiry in which the Commissioner concludes, for example, that a Member has not complied with an obligation under the Code and did not take all reasonable measures to prevent the non-compliance, or where a request for an inquiry was frivolous, vexatious or was not made in good faith, the Commissioner may recommend appropriate sanctions. Only the House of Commons has the right to discipline its own Members, and is responsible for imposing and administering sanctions, including any that may be recommended by the Commissioner. In 2018-2019, our Office issued three inquiry reports under the Code: In the Angus Report I and Angus Report II, both issued on June 14, 2018, I found that Mr. Charlie Angus, Member of Parliament for Timmins–James Bay, contravened subsection 27(2.1) of the Code on two occasions, when he made public comments concerning two separate requests he had made for an inquiry into the conduct of two other Members of Parliament. Mr. Angus' public comments were contrary to the Code because they were made before I had confirmed that the subjects of his complaints had received a copy and before 14 days had elapsed since I received each complaint. However, I did not recommend the imposition of any sanctions, as Mr. Angus had apologized. In the Kusie Report, issued on December 4, 2018, I found that Mrs. Stephanie Kusie, Member of Parliament for Calgary Midnapore, contravened subsection 27(2.1) of the Code in connection with public comments she made concerning a request for an inquiry about another Member of Parliament that she submitted to me. The evidence showed that even though it was the Office of the Leader of the Opposition that sent a copy of Mrs. Kusie's complaint to the media, Mrs. Kusie did make public comments on social media before I had confirmed that the subject of her complaint had received a copy and before 14 days had elapsed since I received her complaint. These public comments were therefore contrary to her obligations under the Code. However, I found that Mrs. Kusie was acting on advice she had received from employees at the Office of the Leader of the Opposition and her non-compliance with the Code was an error in judgment made in good faith. Mrs. Kusie had also apologized for having erred in not waiting before commenting publicly on her complaint. Accordingly, I recommended that no sanctions be imposed. Contacts with Parliament As an independent officer of the House of Commons, I report directly to Parliament, through the Speaker of the House of Commons. I am required to submit an annual report to Parliament by June 30 each year on the administration of the Conflict of Interest Code for Members of the House of Commons. I report on my inquiries under the Code to the Speaker of the House of Commons. I must also submit a list of sponsored travel under the Code to the Speaker of the House of Commons by March 31 each year. I also testify before parliamentary committees about our Office and its work. In 2018-2019, I was summoned to appear before two committees: On May 1, 2018, I appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics about our Office's budgetary submission for the 2018‑2019 Main Estimates.On June 7, 2018, I appeared before the Senate Standing Committee on Legal and Constitutional Affairs during its study of Bill C-50, An Act to amend the Canada Elections Act (political financing). Possible amendments to the Code At the beginning of my mandate, I did not feel I had been Commissioner long enough to be able to put forward possible amendments to strengthen the Conflict of Interest Code for Members of the House of Commons. Moreover, during this fiscal year, my focus was mostly geared towards making recommendations to strengthen the Conflict of Interest Act, as I was asked about it during my appearance before the House of Commons Standing Committee on Access to Information, Privacy and Ethics on May 1, 2018. Having formulated my general recommendations for strengthening the Act, which I have described in general terms in my annual report under that regime, I am now able to identify ways in which the Code could be strengthened. I wish to emphasize that I believe the Code allows our Office to properly fulfill its mandate in the immediate term. I believe that going through this coming year's preparations for the 2019 federal election as well as the process of ensuring compliance among newly elected Members will provide me with a deeper knowledge of the Code. I look forward to tackling this project with our Office during fiscal year 2019-2020. Public communications In last year's annual report, I identified an increase in the number of communications from members of the public and requests for information or interviews from the media as significant trends. Those numbers remained at relatively high levels in 2018-2019. Our Office undertakes a range of initiatives aimed at educating and informing our stakeholders, including ethics practitioners, academics and others with an interest in the field, as well as the media and the general public, about Canada's federal conflict of interest regimes and the role of our Office in administering them. Website: We make a wide range of information available on our Office website, which we update on an ongoing basis. In late 2018-2019, we started work on the development of a new website that will be launched in advance of the October 2019 federal election. Social media: We have used Twitter to communicate more information about our Office and its activities and to retweet items of interest to our Office and the ethics community at large, such as relevant reports from other Canadian conflict of interest commissioners and international organizations. We currently have two Twitter accounts, one for each official language. Counting our followers for both accounts, we have more than doubled our number of Twitter followers (1,023 on March 31, 2019), surpassing the goal of 1,000 that I set for the end of 2018-2019 and increasing our Office's social media reach. Presentations: Giving presentations to various organizations and at various events contributes to public awareness of Canada's federal conflict of interest regimes and increases public understanding of the Commissioner's role and mandate. In November 2018, I delivered the Annual Public Policy Lecture at York University's McLaughlin College. I shared my perspective on the development of ethics regimes governing the conduct of federal officials in Canada and discussed the relevance of conflict of interest regimes to the broader field of ethics and to politics and democracy. Also in November 2018, I gave two presentations to political science students at the University of Ottawa and a senior representative of the Office did so in March 2019. At the March event, we started using an Internet-based audience interaction tool that enables audience members to use their mobile devices to ask questions and participate in live polls. Media and public inquiries: Cognizant of the important role the media play in promoting awareness of the mandate and activities of our Office, I have undertaken to ensure that we provide them with as much information as the regimes that I administer allow. In our dealings with the media, we always take the opportunity to inform and educate them about my role and mandate and the functioning of the Code and the Conflict of Interest Act, in order to help them report accurately about our Office. We issue media advisories and news releases about our work, such as the release of public reports, and publicize other information, such as the imposition of administrative monetary penalties and compliance orders, via Twitter. I participated in 14 interviews with journalists in 2018-2019. We also receive a large volume of inquiries from members of the public. When we respond, we take the time to educate them about our role and mandate and, when their concerns do not fall within our mandate, try to direct them to other organizations that might be better able to assist them. Our Office received 2,499 communications from the public and the media in 2018-2019. This represents a 19% decrease compared to last fiscal year. This may be due to the fact that our Office as a whole received less attention on Twitter, in the news and during Question Period compared to the previous year. We recognize the importance of responding to communications from members of the public and the media in a timely manner and have established service standards to help us do so. The target for achieving those service standards was set at 80%. Media requests were responded to within three hours in 86% of cases. Communications from members of the public were responded to within two business days in 81% of cases. Because of high volumes and in order to maintain the high quality of our responses, we are looking at revising our service standards. Requests for information and interviews from the media 2015-20162016-20172017-20182018-2019143315411260 Communications from the public 2015-20162016-20172017-20182018-20191,3732,0662,6622,239 Collaboration and best practices Our Office acts as an information resource for other jurisdictions and organizations, both domestic and international, by meeting with visiting delegations, responding to information requests and participating in conferences related to conflict of interest and ethics. Our Office continued to work with counterparts in Canada and other countries in 2018-2019, exchanging information about conflict of interest rules and practices and discussing related issues in order to stay abreast of concerns and developments in the field. Domestic outreach In May 2018, our Office participated in the Public Sector Ethics Conference in Toronto, where I took part in a panel discussion on financial disclosure. In September 2018, several representatives of the Office and I attended the annual meeting of the Canadian Conflict of Interest Network (CCOIN), held in St. John's, Newfoundland and Labrador. Created in 1992, CCOIN is made up of conflict of interest commissioners at the federal level and from all Canadian provinces and territories. Our Office has coordinated information gathering for CCOIN since 2010. International outreach Achieving a culture of ethics and integrity is a keystone of good governance. It is also necessary for the effective functioning of democracies. Individuals who hold public office, whether elected or appointed, are expected to always act in the public interest. Their decisions must never be guided by their private interests or those of their friends, families or relatives. A legal framework setting out rules governing conduct helps to ensure the decisions of those who hold public office are made in the public interest. Because these expectations are clearly embedded in the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act, many other countries look to Canada as a model for the development of their own conflict of interest regimes. In July 2018, I helped found a new network of conflict of interest and parliamentary ethics organizations within the Organisation internationale de la Francophonie. The Réseau parlementaire will foster the sharing of best practices among commissioners and other ethics and conflict of interest bodies. The goal is to enhance expertise among the parliaments of Francophonie member countries in order to adopt ethics principles and conflict of interest rules. In October 2018, a senior representative of our Office made a presentation on my behalf at the High-Level Conference on "Strengthening Transparency and Accountability to Ensure Integrity: United Against Corruption." The event, which took place in Croatia, was organized jointly by the Group of States Against Corruption (GRECO) and the Croatian government. GRECO is the Council of Europe's anti-corruption monitoring body. In December 2018, several representatives of our Office attended the annual conference of the Council on Governmental Ethics Laws (COGEL), in Philadelphia. COGEL is a U.S.‑based, international not-for-profit organization of government ethics practitioners of which our Office is a member. A number of Canadian conflict of interest and integrity offices are represented as well. A senior representative of our Office participated in a panel discussion about reporting obligations. In March 2019, our Office was represented at the Global Anti-Corruption and Integrity Forum hosted in Paris by the Organisation for Economic Co-operation and Development (OECD). In 2018-2019, a number of our international counterparts approached our Office to organize delegation visits. During such visits, we provide a brief overview of the Canadian ethical framework, as well as the role and mandate of our Office. They are also an opportunity for our Office to learn firsthand about the ethics regimes in other countries. In November 2018, we hosted incoming delegations from the Haute Autorité de la Bonne Gouvernance of the Ivory Coast, and the Anti-Corruption and Civil Rights Commission of South Korea. Transparency I believe Canadians should receive as much information as possible about the work of our Office. In last year's annual report, I committed to making our Office and its work as transparent as possible, while respecting the strict confidentiality requirements set out in the Conflict of Interest Code for Members of the House of Commons, particularly regarding inquiries and advice provided to Members. While respecting these constraints and other considerations, we are as forthcoming with Parliament, the media and the public as we are permitted to be under the Code. In support of that commitment, in 2018-2019 we began releasing quarterly statistical reports. The purpose is to align our activities with our mission, assess our workload and identify current trends. The quarterly statistical report contains data on various activity areas, including the provision of direction and advice to Members and public office holders, education and outreach, and enforcement. It also includes figures on how our Office meets its service standards. We also use the data internally to gauge our workload and performance, and to measure progress towards the objectives set out in our Office's strategic plan. The data also contributes to strategic decision making. Our quarterly statistical report is released on the last business day of the month following the end of the quarter for which the data is compiled. The aggregated data for 2018-2019 is published in this report and in the annual report under the Conflict of Interest Act. Our tools The success of our Office’s mission is supported by the strength of our people, our plan and our infrastructure. Our people I recognize that any accomplishments I may have as Commissioner depend on the hard work and dedication of our employees at all levels within the organization. Accordingly, I have taken steps to ensure our Office invests in employees’ training and professional development and provides the tools and equipment they need to perform their jobs effectively and safely. I have also acted to ensure it offers a respectful, diverse and inclusive workplace and am mindful of the importance of an appropriate work-life balance. The Quality Workplace Promotion Committee, which I established early in my tenure as Commissioner to promote employees’ well-being, is playing a key role in some of these important areas. One of the initiatives introduced through the Committee is the implementation in our Office of the Canadian Mental Health Association’s Not Myself Today program. It focuses on building greater awareness and understanding of mental health, reducing stigma, and fostering safe and supportive work cultures. Our plan A rolling three-year strategic plan, which is published on the Office website, helps guide our projects and activities in support of our mission. It identifies three key priorities and the means by which we will achieve them. In 2018-2019, we completed a number of specific projects and activities, identified elsewhere in this report, that contributed directly to the following priorities: Build and improve communications and outreach processesModernize technology and information management structuresMaintain operational excellence Our strategic plan is an evergreen tool that is meant to capture the Commissioner's vision. In January 2019, one year after I started my mandate as Commissioner, we conducted a strategic plan refresh exercise to pinpoint projects to be undertaken in the next fiscal year. Those discussions led to a small shift in our priorities, which were identified as follows: Build and improve communications and outreach processesImprove the Office's mechanisms for conflict of interest preventionMaintain operational excellence (tools and people) These priorities will be supported by specific projects and activities that we have identified. Progress against our strategic plan will continue to be monitored on an ongoing basis and I will report on it in future annual reports to Parliament. Our infrastructure We have a sound internal management framework in place to ensure the prudent stewardship of public funds, the safeguarding of public assets and the effective, efficient and economical use of resources. Because I am an independent officer of the House of Commons and our Office is a parliamentary entity, we are not generally subject to legislation governing the administration of the public service or to Treasury Board policies and guidelines. We try to ensure that our resource management practices are, to the greatest extent possible, consistent with those found in the public service and in Parliament. We also look at various policies and practices of other parliamentary entities and generally follow what they do, unless there is a valid reason for our Office to take a different approach. Our Office's financial statements are audited each year by an independent external auditor and no concerns have been raised. A Financial Resources Summary appended to this report outlines our financial information for the 2018‑2019 fiscal year. In November 2018, we launched an upgraded Integrated Case Management System. All information from our old system was migrated to the new one, supported by the House of Commons' information technology group. Several customizations that had been made previously were replaced with more streamlined solutions so operations were not interrupted. Our upgraded information technology infrastructure is compatible with existing systems and allows our Office to explore new technology options for delivering our mandate. Because of the scope of this transition, we are still dealing with technical and procedural issues that we are working to resolve. Distribution of positions within our Office Commissioner's Office (4)Advisory and Compliance (18)Investigations and Legal Services (8)Communications, Outreach and Planning (8)Corporate Management (11) Our challenges The way I implement my mandate as Commissioner can be impacted by developments in the external environment. Some of those may be viewed as challenges and others as opportunities. In my view, however, they all represent the potential for positive change. Maintaining and enhancing public confidence One of the purposes of the Conflict of Interest Code for Members of the House of Commons is 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." By helping Members of the House of Commons avoid and prevent conflicts between private and public interests, our Office plays an important role in enhancing Canadians' confidence and trust in the integrity of public officials and the public institutions in which they serve. Measuring the impact our Office has had on that public confidence would be extremely difficult, if not impossible, and certainly very costly. We have relied, instead, on data published by credible international organizations that provide a broad indication of levels of public trust in Canada. The Latin American Public Opinion Project, a centre for excellence in survey research, conducts a periodic study of 34 countries in the Western Hemisphere, including Canada, called the AmericasBarometer. Its report, AmericasBarometer: The Public Speaks on Democracy and Governance in the Americas, issued in June 2017, notes that public trust in the Canadian Parliament is low, but that it is marginally stronger since 2012. Transparency International's Corruption Perceptions Index ranks 180 countries and territories by their perceived levels of public sector corruption. In its 2018, Canada was ranked as the 9th least corrupt country in terms of public perception. In 2017, Canada was ranked 8th. The Edelman Trust Barometer is an annual survey that explores trust in business, government, non-governmental organizations and media across 27 global markets. Its 2019 edition demonstrates that while Canadians' trust in government has increased slightly, it remains neutral. We are closely monitoring these types of reports to determine trends that could be useful for the day-to-day operations of our Office. In my opinion, transparency remains the main tool that our Office has at its disposal to increase public confidence and trust in Members and in the House of Commons, in support of one of the Code's purposes as stated above. This year, the public registry was visited 29,713 times. We will continue to collect this data going forward in order to measure its reach and to make further observations about the role and impact of our Office in maintaining and enhancing public confidence. Leveraging new technology Just as we have made use of new technologies to increase the reach of our education and outreach activities and their ease of access, I believe there are opportunities to leverage new technologies so our Office can better assist Members in identifying potential conflicts of interest in order to prevent them from developing. For example, I believe artificial intelligence could have great potential in the development of an electronic oversight tool. It is not beyond the realm of possibility that one day we could have a system that contains data not only on Members, such as their assets and liabilities, but also on the official decisions they are making or have made. The system would be able to automatically generate red flags that would alert individual Members as well as the Commissioner, making it possible to avoid conflicts of interest or to address them right away. We are, of course, a long way from achieving such a system, and there are issues that would have to be addressed, such as how to obtain and input data on decisions, as well as privacy considerations. In October 2015, our Office launched a secure declaration portal to facilitate the process by which Members meet their reporting requirements. The majority of declarations are approved or submitted through the portal. As the portal has become a popular tool, our Office is considering ways to increase its potential in order to improve efficiency. Harnessing the use of technology to improve compliance is a trend that is being seen on a global level. Our Office was represented at the Organisation for Economic Co‑operation and Development’s 2019 Integrity Forum, whose theme was “Technology for Trust.” The Forum explored the many ways technology is being used by governments and organizations to implement and improve their ethics frameworks. As well, an Office employee recently attended seminars focusing on artificial intelligence and business analytics in order to help us to start incorporating technology in more of our internal processes. Election readiness With a federal election scheduled to take place in October 2019, our Office’s workload is expected to increase significantly, given that we will have to guide newly elected Members of the House of Commons through the initial compliance process. We started preparing for the election in 2018‑2019. For example, we worked on processes for the hiring of employees and students to help with the increased workload. We updated documents and improved our fillable electronic forms to make it easier for Members to complete their disclosure statement. We also offered presentations to party caucuses and independents focusing on the election period. Appendices Financial resources summary (thousands of dollars)Program Activity 2017-2018 Actual Spending 2018-2019 Alignment to Government of Canada Outcomes 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 5,973 6,134 6,134 5,827 Government AffairsContributions to employee benefit plans665734734691 Total spending6,6386,8686,8686,518 Plus: cost of services received without charge1,148n/an/a1,110 Net cost of department 7,7866,8686,8687,628 The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. Before each fiscal year, the Commissioner has his Office prepare an estimate of its budgetary requirements. The estimate is considered by the Speaker of the House of Commons and then transmitted to the President of the Treasury Board, who lays it before the House with the estimates of the Government of Canada for the fiscal year. The mandate of the Standing Committee on Access to Information, Privacy and Ethics includes reviewing and reporting on our Office's effectiveness, management and operations, together with its operational and expenditure plans. Complete audited financial statements can be found on our website. Our history ​The Office of the Conflict of Interest and Ethics Commissioner was created in July 2007 when the Conflict of Interest Act, passed in 2006 as part of the Federal Accountability Act, came into effect. At that time, responsibility for administering the Conflict of Interest Code for Members of the House of Commons was transferred to the Conflict of Interest and Ethics Commissioner. The Code is appended to the Standing Orders of the House of Commons, the permanent written rules under which the House regulates its proceedings. 2004 Conflict of Interest Code for Members of the House of Commons was adopted. An Ethics Commissioner, created as a separate parliamentary entity, replaced the position of Ethics Counsellor; Bernard Shapiro appointed to the position 2006Parliament of Canada Act was amended, creating position of Conflict of Interest and Ethics Commissioner2007Mary Dawson was appointed first Conflict of Interest and Ethics Commissioner and assumed responsibility for administering Conflict of Interest Code for Members of the House of Commons2007-2015Conflict of Interest Code for Members of the House of Commons was amended four times (in 2007, 2008, 2009 and 2015)2017Mario Dion was appointed second Conflict of Interest and Ethics Commissioner

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 my 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, 2018, to be tabled in the House of Commons on June 12, 2018.​ This fulfills my obligations under paragraph 90(1)(a) of the Parliament of Canada Act.​ Sincerely, Mario DionConflict of Interest and Ethics Commissioner Commissioner's message I have been working diligently to honour the confidence and trust that the House of Commons placed in me when it confirmed my appointment as Commissioner, effective January 9, 2018, with a mandate to administer the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. Conflict of interest regimes are important elements of the Canadian ethical framework, the rules governing the conduct of public officials. I believe ethical behaviour starts at the top, with our elected and appointed officials setting the tone and example that we expect others to follow. They must therefore be held to high standards of conduct. I am very honoured to have the opportunity, as Conflict of Interest and Ethics Commissioner, to contribute to public sector ethics in Canada. Before I came to the Office, I expected to find it well-organized, and indeed I did. It had sound infrastructure and competent, hardworking staff. I was pleased to discover a situation where I could only hope to improve on what had already been built, in support of my goals of rigour, transparency and predictability. It was, and remains, my intention to maintain those aspects that are already working well and to only make changes where I believe we can do better. Under my leadership, our Office will continue to administer the Act and the Code efficiently and effectively, while taking a new approach to some aspects of our work. My staff and I will do everything we can to be as transparent as possible, while respecting confidentiality requirements. This is reflected in a renewed focus on education and outreach in our communications with public office holders, Members of the House of Commons, the media, other stakeholders and Canadians. In seeking to ensure predictability, I recognize that public office holders and Members need to understand their obligations under both regimes. They need to be able to rely on consistent advice from our Office. They also need to know I will strictly enforce the Act and the Code. While acknowledging that much of what is reported here reflects the accomplishments of my predecessor, I am proud of all the achievements of our Office in 2017-2018. I look forward to reporting on its work in the years ahead as I continue to fulfill my mandate, drawing on the skills and experience I have gained in over 35 years of public service. Our history The Office of the Conflict of Interest and Ethics Commissioner was created in July 2007 when the Conflict of Interest Act, passed in 2006 as part of the Federal Accountability Act, came into effect. It is important to understand, however, that significant milestones had already been achieved in the preceding decades. Pre-2004Members of House of Commons were subject to conflict of interest rules under Parliament of Canada Act and Standing Orders of the House of Commons. 2004Conflict of Interest Code for Members of the House of Commons was adopted. Parliament of Canada Act amended to create position of Ethics Commissioner; Bernard Shapiro appointed to position. 2006Federal Accountability Act amended Parliament of Canada Act, creating position of Conflict of Interest and Ethics Commissioner. 2007Mary Dawson was appointed first Conflict of Interest and Ethics Commissioner and assumed responsibility for administering Conflict of Interest Code for Members of the House of Commons. 2007-2015Conflict of Interest Code for Members of the House of Commons was amended four times (in 2007, 2008, 2009 and 2015). 2017Mario Dion was appointed second Conflict of Interest and Ethics Commissioner Our mission “Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.” In February 2018, I developed a new mission statement in support of the mandate of our Office, which is to administer the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act. The new mission statement lays out the approach that we will be taking under my leadership. It strives to summarize the key parts of a complex set of ideas in a few words. Our Office is an independent ​institution that serves an important purpose: to enhance Canadians’ trust and confidence in the Members of Parliament they elected and in the public office holders appointed by the government. It is responsible for administering two regimes that are similar but distinct and has various means of doing so, some of them preventive, others reactive. Each word of the statement is carefully chosen to refer to a specific aspect of the Code or the Act or, more broadly, an intent common to both regimes. The three pillars of our approach are information, advice and sanctions. We inform Members and public office holders of their obligations under the Code and the Act, through enhanced education and outreach initiatives. We also keep Parliament apprised of our activities, through our reports and through my appearances before parliamentary committees. When Members and public office holders seek advice from our Office, we provide them with clear, consistent direction. We advise them on how to comply not only with the rules themselves, but with the spirit in which they were written. I will enforce the Code and the Act, and by doing so, investigate possible contraventions of both regimes and make use of appropriate sanctions when contraventions are found. Our stakeholders The Conflict of Interest Code for Members of the House of Commons applies to conflicts of interest of all Members of the House of Commons when carrying out the duties and functions of their office as Members of the House, including Members who are ministers of the Crown or parliamentary secretaries. It sets out a number of obligations aimed at preventing conflicts between private and public interests and prohibits various actions that could give rise to such conflicts. Members who are ministers and parliamentary secretaries are also subject to the Conflict of Interest Act, which imposes additional reporting obligations and compliance measures on them, as reporting public office holders. This annual report focuses on the activities of our Office in relation to all Members of the House of Commons who were subject to the Code during 2017-2018. Members of the House of Commons on March 31, 2018 Ministers (30)9%Parliamentary secretaries (35)10%Other Members of the House of Commons (272)81% Note: One seat was vacant on March 31, 2018 Our achievements Administering the Conflict of Interest Code for Members of the House of Commons involves a range of activities. They include informing Members about their obligations under the Code upon confirmation of their election, providing them with confidential advice, receiving and reviewing their confidential disclosure statements, preparing summaries for public disclosure, maintaining a public registry of declarable information, investigating possible contraventions of the Code and reporting to Parliament. These and other activities are supported by our Office infrastructure. Our Office works with Members from the time they are elected to help them achieve compliance with the Code’s initial reporting requirements and maintain compliance with the Code throughout their terms of office. The first step for Members to achieve compliance is to prepare a confidential disclosure statement of detailed information on assets, liabilities, outside activities and other interests for themselves and immediate family members. This statement must be submitted to our Office no later than 60 days after notice of the Member’s election is published in the Canada Gazette.​ Our Office reviews the information in the disclosure statements and provides Members with advice on achieving and maintaining compliance with the Code. We might also request further information, such as financial statements, to clarify or confirm the information provided, and may also recommend specific compliance measures to prevent conflicts of interest. Once all of the required information has been obtained, we prepare a disclosure summary. Members have 60 days to review and sign their disclosure summaries, which are then placed in the public registry maintained by our Office. Our Office maintains a Members' Compliance Status Report that identifies where each Member is in the initial compliance process on a specific day. This report is available on our website and is updated regularly after general elections. This year, 34 initial compliance processes were completed. Members also face a number of ongoing reporting requirements throughout their term in office. They must review their compliance arrangements with advisors from our Office every year and update information previously disclosed to our Office. In addition to this annual review process, they must inform us of any​ material change to the information contained in their disclosure statement within 60 days of the change. Members must also publicly declare any acceptable gifts related to their position that have a value of $200 or more, within 60 days after acceptance. There were 222 annual reviews done this year. The Code allows Members to accept sponsored travel that arises from or relates to their position. In cases where the costs covered by the sponsor exceed $200, Members must disclose the sponsored travel within 60 days after the end of the trip. Public declarations of sponsored travel by Members are posted in our Office’s public registry. By March 31 of each year, our Office must also produce a list of sponsored travel for the previous calendar year. The List of Sponsored Travel 2017 is available on our website.​ Advice and education Members of the House of Commons frequently seek advice from our Office. In addition to providing Members with specific direction on how to deal with various situations, we issue, update and disseminate a variety of informational materials about the requirements of the Code, including backgrounders and advisory opinions about Members’ obligations, which are posted on our website. We also offer presentations to party caucuses every year in order to remind Members about their obligations under the Code.​ Public declarations made by Members of the House of Commons 2014-20152015-20162016-20172017-2018Declarations of gifts or other benefits20143352Declarations of sponsored travel87278497Declarations of material changes37578995 Instances in which Members of the House of Commons sought direction and advice 2014-20152015-20162016-20172017-2018499409628814 Types of direction and advice given to Members of the House of Commons in 2017-2018 Material changes320General obligations243Gifts and other benefits191Letters of support and fundraising60 A greater focus on education Upon taking office, I signalled that education and outreach would be a key focus of my approach in order to help Members understand and meet their obligations under the Conflict of Interest Code for Members of the House of Commons. We will leverage modern technology to implement education and outreach initiatives. With a greater presence on Twitter, we have already begun making more use of the possibilities this information-sharing platform has to offer. We will make available new options such as webinars and online videos for the information sessions offered to Members of Parliament at the start of their terms and during their time in office. By offering methods that accommodate their busy schedules, I am confident that we will be able to reach Members more efficiently. Our Office undertakes a range of initiatives aimed at educating and informing other stakeholders and the Canadian public about the conflict of interest regimes and the role of our Office in administering them. It also facilitates my reporting to Parliament and exchanges information with other jurisdictions. We received 3,073 communications from the public and the media in 2017-2018. This represents a 29% increase in volume compared to the previous year.​ In the interests of transparency, and while guaranteeing that confidentiality requirements will be strictly met, I believe Canadians should receive as much information as possible about what our Office is doing. The media also pla​y a role in promoting awareness of the mandate and activities of our Office.​ Communications from the public 2014-20152015-20162016-20172017-20185971,3732,0662,662 Requests for information and interviews from the media 2014-20152015-20162016-20172017-2018140143315411 ​Service standards Our Office recognizes the importance of responding to requests for advice or information from Members of the House of Commons, public office holders, members of the public and the media in a timely manner, and has established service standards to help us do so. The target for achieving those service standards was set at 75%. Results All stakeholders, including public office holders, were contacted within 3 days of our Office being notified of their appointment 81% of casesRequests from all stakeholders, including public office holders, were dealt with within 3 business days 93% of casesMedia requests were responded to within 3 hours 87% of casesPublic requests were responded to within 2 business days 85% of cases Contacts with Parliament There were six appearances before parliamentary committees in relation to our Office and its work in 2017-2018: House of Commons Standing Committee on Procedure and House Affairs, regarding: Bill C-50 amending the Canada Elections Act (political financing), October 17, 2017 House of Commons Standing Committee on Access to Information, Privacy and Ethics, regarding: ​Main Estimates 2017-2018, May 2, 2017Certificate of nomination of Mario Dion to position of Conflict of Interest and Ethics Commissioner, December 12, 2017The Trudeau Report, January 10, 2018Review of the Conflict of Interest Act, February 8, 2018 House of Commons Standing Committee on Official Languages, regarding:​​Air Canada’s implementation of the Official Languages Act, October 17, 2017​​ Sanctions I am not empowered to impose sanctions under the Conflict​​ of Interest Code for Members of the House of Commons. I may, however, recommend sanctions in my inquiry reports. Section 28 of the Code provides that, following an inquiry in which the Commissioner concludes, for example, that a Member has not complied with an obligation under the Code and did not take all reasonable measures to prevent the non-compliance, or where a request for an inquiry was frivolous, vexatious or was not made in good faith, the Commissioner may recommend appropriate sanctions. Only the House of Commons has the right to discipline its own Members, and is responsible for imposing and administering sanctions, including any that may be recommended by the Commissioner.​ Inquiries I may conduct investigations, called inquiries, of possible contraventions of the Conflict of Interest Code for Members of the House of Commons. All inquiry reports are made public. Any Member who has reasonable grounds to believe that another Member has contravened the Code may ask me to investigate by submitting a signed, written request that identifies the alleged non-compliance and provides reasonable grounds to believe that the Code has been contravened. When I receive a valid request for an inquiry, I must forward the request without delay to the Member named in it and give him or her 30 days to respond. After receiving the Member’s response, our Office conducts a preliminary review to determine if an inquiry is warranted. Within 15 working days of receiving the Member’s response, we notify the originator of the request and the Member named in it whether or not an inquiry will be conducted. Under paragraph 27(5.1)(iii) of the Code, I may describe the reasons for not proceeding with an inquiry where the matter to which the inquiry relates has already been made public. While this has not yet occurred in the 14 years since the Code was adopted, the House of Commons may direct me, by way of resolution, to conduct an inquiry. I also have the discretion to conduct an inquiry on my own initiative. From time to time, our Office receives information about possible contraventions of the Code, including through media reports or complaints from members of the public. In each instance, we review the information to determine whether the concern raised falls within the mandate of our Office and whether there is reason to believe that a contravention of the Code has occurred. Some of these preliminary reviews lead to inquiries; in other cases, an inquiry is not found to be warranted and the file is closed.​ Concerns reviewed by our Office 2014-20152015-20162016-20172017-2018Case files closed without proceeding to an inquiry8367Case files that warranted an inquiry0011Case files still under consideration at fiscal year-end1003 Source of concerns raised Members of general public7Members of the House of Commons4 Persons who are the subject of concerns raised Members of the House of Commons10Person not subject to Code1 Nature of concerns raised Outside activities1Gifts or other benefits2Making decisions, or seeking to influence decisions, that would further a private interest11 Note: Certain case files encompassed more than one concern In 2017-2018, our Office issued one investigation report under the Conflict of Interest Code for Members of the House of Commons: In The Trudeau Report, issued on December 20, 2017, the Right Honourable Justin Trudeau, Prime Minister of Canada, was found not to have contravened the Code when he accepted gifts of vacations, including private travel, on behalf of himself and his family, on a private island owned by the Aga Khan, who chairs institutions that have official dealings with the Government of Canada. Mr. Trudeau, in his capacity as Member of Parliament for Papineau, did not discuss any House of Commons business with the Aga Khan or his representatives, or participate in any debate or vote in the House of Commons related to the Aga Khan or his representatives. As a result, Mr. Trudeau did not contravene subsection 14(1), which prohibits Members and members of their family from accepting gifts that might reasonably be seen to have been given to influence them in the exercise of a duty or function of their office.​ ​Collaboration and best practices Our Office continued to work with counterparts in Canada and other countries in 2017-2018, exchanging information about conflict of interest rules and practices and discussing related issues in order to stay abreast of issues and developments in the field. In September, our Office was represented at the annual meeting of the Canadian Conflict of Interest Network (CCOIN), held in Charlottetown. Created in 1992, CCOIN is made up of conflict of interest commissioners at the federal level and from all Canadian provinces and territories. Our Office has coordinated information-gathering for CCOIN since 2010. In December, members of our Office attended the annual conference of the Council on Governmental Ethics Laws (COGEL), in Toronto. COGEL is a U.S.-based, international not-for-profit organization of government ethics practitioners of which our Office is a member. In March, I signed a memorandum of understanding with the Commissioner of Lobbying to cooperate on education and outreach. Among other activities, we will hold joint information sessions, including webinars, for individuals affected by the work of both offices. As part of our international outreach, we responded to information requests from Australia, Indonesia, Ireland, Kazakhstan, South Korea, the Group of States against Corruption (GRECO) and ParlAmericas. Our tools Strategic plan We have adopted a Strategic Plan for 2018-2021 that sets the course for our Office for the next three years and beyond. It will help guide our priorities and align our activities in light of our increasing workload. (Please refer to Significant Trends ​bellow.) Our strategic plan, which is published on our Office’s website, identifies three key priorities and the means by which we will achieve them: Build and improve communications and outreach processesModernize technology and information management structuresMaintain operational excellence Progress against our strategic plan will be continually monitored and I will report on it in my future annual reports to Parliament. Brand identity The beginning of my mandate was an ideal time to rethink the brand identity of our Office, which had just entered its second decade, in support of our mission. I also wanted to introduce a modern look and feel while honouring our Office’s existing standards of professionalism.​ My staff and I partnered with a creative firm on the development of a brand identity that I believe offers an effective visual representation of our mission. It communicates the independent and impartial character of our Office, the nature of the work we do and the way we do it—with integrity, rigour and consistency. Branding elements include three complementary combinations of colours and designs that represent various facets of our identity, including our role in helping safeguard the public interest and our forward-looking approach. All feature the Canada Coat of Arms in recognition of my status as an Officer of the House of Commons. Investments in our people I have established a Quality Workplace Promotion Committee whose goal is to promote the well-being of our employees. It will support a healthy workplace and implement initiatives to sensitize our staff on issues affecting the work environment, such as diversity, inclusion, mental health and wellness, professional development, employee and management engagement, and the importance of a respectful workplace.​ Office infrastructure As I noted earlier, the administration of the conflict of interest regimes is supported by the infrastructure of our Office. It has a sound internal management framework in place to ensure the prudent stewardship of public funds, the safeguarding of public assets and the effective, efficient and economical use of resources. Because I am an independent Officer of the House of Commons and our Office is a parliamentary entity, we are not generally subject to legislation governing the administration of the public service or to Treasury Board policies and guidelines. We try to ensure that our resource management practices are, to the greatest extent possible, consistent with those found in the public service and in Parliament. We also look at various policies and practices of other parliamentary entities and generally follow what they do, unless there is a valid reason for our Office to take a different approach. Our Office’s financial statements are audited each year by an independent external auditor and no concerns have been raised. A Financial Resources Summary appended to this report outlines our financial information for the 2017-2018 fiscal year. In support of our strategic objective of modernizing technology and information management structures, in 2017-2018 we replaced our financial management system and started working to upgrade our electronic case management system. We continued to make our operations more efficient in 2017-2018 by implementing a paperless office initiative and expanding our use of a document management system that had been piloted as a replacement of our Office’s shared electronic drive.​ Commissioner's Office 4 positions Advisory and Compliance 18 positions Investigations and Legal Services 8 positions Communications, Outreach and Planning 8 positions Corporate Management 11 positions Our challenges and opportunities​ Although it is always difficult to predict with any accuracy what important changes will occur that will affect the operations of our Office, I believe it is nimble enough to reallocate its resources to meet emerging long-term trends. At this moment, we observe a marked increase in relation to four distinct areas of our operations, as discussed earlier. It is also possible that other things will happen that we are not in a position to predict at this time. Significant trends Our Office is facing several trends that have contributed to a significant increase in our workload. We have received a growing number of requests for advice from Members of the House of Commons, including requests for advice about the acceptability of gifts. While dealing with more requests takes more resources, this trend is indicative, I believe, of a growing desire on the part of Members of the House of Commons to take steps to comply with the Code. Transactions with Members of the House of Commons 2014-20152015-20162016-20172017-2018Advice sought by Members of the House of Commons 499409628814Initial compliance completed811618934Communications sent by our Office24364143228Public registry postings273255478476 Instances of advice and direction given to Members of the House of Commons 2008-20092009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-2018442300486264605534499409628814 Instances of advice and direction relating to gifts (Data on requests relating to gifts is only available as of 2010-2011) 2010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-201880519998111129187191 There has also been an increase in the number of communications from members of the public and requests for information or interviews from the media. Communications from the public 2008-20092009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-20184295815445938391,0975971,3732,0662,662 Requests for information from the media 2008-20092009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-2018281744102185213140143315411 677 media mentions of Office18,960 tweets mentioning OfficeOffice was mentioned in 68% of Question Periods in House of Commons Providing consistent advice When Members seek advice from our Office on how to comply with the Code, it is important that the advice they receive be clear and consistent. I recognize that there is no one-size-fits-all approach that can apply to every situation or even, in some cases, to situations that may appear similar, and that the advice provided by our Office must take into account the specific circumstances of individual Members. I acknowledge, however, the importance of ensuring consistency, in order to reduce uncertainty and confusion and to ensure that Members feel confident the advice they receive is fair and appropriate. Fairness also requires that different Members in the same situation receive the same advice over time. One way I hope to address this challenge is by continuing to develop internal tools to record my interpretations of the Code and make them accessible to employees of our Office. I will also maintain an ongoing dialogue with those employees who provide advice to Members.​ One of my key roles as Commissioner is to interpret the Code. Over the coming months, our Office will review all of the informational materials that have been published on our website for the guidance of Members, in order to ensure that they adequately reflect current interpretations of various aspects of the Code. Conducting Enquiries with due dispatch I recognize that, when our Office conducts an inquiry, the Member who is the subject of the inquiry may experience uncertainty and concern. This is particularly true in cases where the identity of the individual is public knowledg​​e, as this can lead to speculation and possible reputational damage, even when the individual is eventually found not to have contravened the Code. I will ensure that our Office conducts inquiries with due dispatch, while still conducting them thoroughly, with proper diligence and being careful to respect procedural fairness.​ Better targeting education and outreach In October 2017, a brief survey was sent to Members of the House of Commons via email to gauge their satisfaction with the outreach and education tools produced by our Office and to identify possible areas for improvement. We received 113 responses, accounting for about one-third of Members. The following conclusions were drawn from our analysis of the survey results: Members are viewing most of their information electronically;Members would like to see more material explaining their obligations under the Code;Members would like to receive frequent reminders of the rules, as well as email updates when possible;​Members would like our Office to provide training for their staff. Based on these findings, we are implementing changes in the way we share information with Members. For example, we have created a​ presentation targeted to Members’ staff that will be offered in the fall. We are also moving away from a traditional “classroom” approach. In 2018-2019, we will develop webinars, online videos and other products using new media in order to inform and educate Members about their obligations under the Code. Operating within a static budget I am impressed by the fact that even though our Office’s workload has increased substantially in its almost eleven years of operation and we have faced higher technology costs and other inflationary pressures, our Office has maintained an annual operating budget that is no higher today than it was in its first full year of operation. In its earlier years, our Office had relatively low expenditures compared with its allotted budget, which gave it room to build an effective organization. However, our Office today has little flexibility with which to meet unforeseen demands, such as a marked increase in investigation requests. Although we remain committed to using our resources effectively, efficiently and economically, it does not appear that meeting the growing demands on our Office at current funding levels will be possible over the course of my seven-year mandate. Maximizing transparency I am committed to making our Office and its work as transparent as possible. This is a challenge because of the strict confidentiality requirements set out in the Conflict of Interest Code for Members of the House of Commons, particularly regarding preliminary reviews and inquiries, as well as advice provided to Members. ​There may also be other valid reasons in some cases for not divulging information even when we are permitted to do so. For example, I have chosen not to identify the subjects of several ongoing inquiries at this time in order to safeguard their privacy against the possibility of undue reputational damage. If those inquiries proceed, we will report publicly on the findings. While respecting these constraints and other considerations, we will be as forthcoming with Parliament, the media and the public as we are permitted to be under the Code.​ Appendix Financial resources summary (thousands of dollars) Program Activity 2017-2018 Actual Spending 2018-2019 Alignment toGovernment of CanadaOutcomes 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 5,973 6,134 6,134 5,827 Government AffairsContributions to employee benefit plans665734734691 ​Total spending6,6386,8686,8686,518 Plus: cost of services received without charge1,148n/an/a1,110 Net cost of department 7,7866,8686,8687,628 The b​udget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. The Speaker of the House considers the estimates for the Office and transmits them to the President of the Treasury Board for inclusion in the estimates of the Government of Canada. The Standing Committee on Access to Information, Privacy and Ethics has within its mandate the role to review and report on the effectiveness, management and operations together with the operational and expenditure plans relating to the Office. Complete audited financial statements appear on our 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 Mr. Speaker: I am pleased to submit to you my 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, ​2018, for tabling in the Senate on June 5, 2018. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Mario DionConflict of Interest and Ethics Commissioner Dear Mr. Speaker: I am pleased to submit to you my 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, 2018, for tabling in the House of Commons on June 5, 2018. This fulfills my obligations under paragraph 90(1)(b) of the Parliament of Canada Act. Sincerely, Mario DionConflict of Interest and Ethics Commissioner Commissioner's message I have been working diligently to honour the confidence and trust that the House of Commons placed in me when it confirmed my appointment as Commissioner, effective January 9, 2018, with a mandate to administer the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. Conflict of interest regimes are important elements of the Canadian ethical framework, the rules governing the conduct of public office holders and Members of Parliament. I believe ethical behaviour starts at the top, with our elected and appointed officials setting the tone and example that we expect others to follow. They must therefore be held to high standards of conduct. I am very honoured to have the opportunity, as Conflict of Interest and Ethics Commissioner, to contribute to public sector ethics in Canada. Before I came to the Office, I expected to find it well-organized, and indeed I did. It had sound infrastructure and competent, hardworking staff. I was pleased to discover a situation where I could only hope to improve on what had already been built, in support of my goals of rigour, transparency and predictability. It was, and remains, my intention to maintain those aspects that are already working well and to only make changes where I believe we can do better. Under my leadership, our Office will continue to administer the Act and the Code efficiently and effectively, while taking a new approach to some aspects of our work. My staff and I will do everything we can to be as transparent as possible, while respecting confidentiality requirements. This is reflected in a renewed focus on education and outreach in our communications with public office holders, Members of the House of Commons, the media, other stakeholders and Canadians. In seeking to ensure predictability, I recognize that public office holders and Members need to understand their obligations under both regimes. They need to be able to rely on consistent advice from our Office. They also need to know I will strictly enforce the Act and the Code. While acknowledging that much of what is reported here reflects the accomplishments of my predecessor, I am proud of all the achievements of our Office in 2017-2018. I look forward to reporting on its work in the years ahead as I continue to fulfill my mandate, drawing on the skills and experience I have gained in over 35 years of public service. Our history The Office of the Conflict of Interest and Ethics Commissioner was created in July 2007 when the Conflict of Interest Act, passed in 2006 as part of the Federal Accountability Act, came into effect. It is important to understand, however, that significant milestones had already been achieved in the preceding decades. 1973Prime Minister Pierre Elliott Trudeau introduced conflict of interest guidelines for cabinet ministers; guidelines for various groups of public servants and Governor-in-Council appointees were announced1974Prime Minister Pierre Elliott Trudeau appointed David Taylor as Canada’s first federal conflict of interest administrator, an Assistant Deputy Registrar General; office established within former Department of Consumer and Corporate Affairs1985Prime Minister Brian Mulroney issued Conflict of Interest and Post-Employment Code for Public Office Holders, consolidating in one document the rules for ministers, parliamentary secretaries, ministerial staff and Governor-in-Council appointees1994Prime Minister Jean Chrétien appointed Howard Wilson to new position of Ethics Counsellor, which replaced Assistant Deputy Registrar General; Ethics Counsellor reported to Prime Minister2004An Ethics Commissioner, created as a separate parliamentary entity, replaced Ethics Counsellor; Bernard Shapiro appointed to the position; Conflict of Interest Code for Members of the House of Commons adopted2006Conflict of Interest Act was passed as part of Federal Accountability Act, replaced Conflict of Interest and Post-Employment Code for Public Office Holders; position of Conflict of Interest and Ethics Commissioner was created2007Conflict of Interest Act came into effect; Mary Dawson appointed first Conflict of Interest and Ethics Commissioner2017Mario Dion was appointed second Conflict of Interest and Ethics Commissioner Our mission “Our Office provides independent, rigorous and consistent direction and advice to Members of Parliament and federal public office holders, conducts investigations and, where necessary, makes use of appropriate sanctions in order to ensure full compliance with the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.” In February 2018, I developed a new mission statement in support of the mandate of our Office, which is to administer the Conflict of Interest Act and the Conflict of Interest Code for Members of the House of Commons. The new mission statement lays out the approach that we will be taking under my leadership. It strives to summarize the key parts of a complex set of ideas in a few words. Our Office is an independent institution that serves an important purpose: to enhance Canadians’ trust and confidence in the Members of Parliament they elected and in the public office holders appointed by the government. It is responsible for administering two regimes that are similar but distinct and has various means of doing so, some of them preventive, others reactive. Each word of the statement is carefully chosen to refer to a specific aspect of the Act or the Code or, more broadly, an intent common to both regimes. The three pillars of our approach are information, advice and sanctions. We inform public office holders and Members of their obligations under the Act and the Code, through enhanced education and outreach initiatives. We also keep Parliament apprised of our activities, through our reports and through my appearances before parliamentary committees. When public office holders and Members seek advice from our Office, we provide them with clear, consistent direction. We advise them on how to comply not only with the rules themselves, but with the spirit in which they were written. I will enforce the Act and the Code, and by doing so, investigate possible contraventions of both regimes and make use of appropriate sanctions when contraventions are found. Our stakeholders The Conflict of Interest Act applies to ministers, parliamentary secretaries, the Chief Electoral Officer, the Parliamentary Budget Officer, ministerial staff, ministerial advisers and most other Governor-in-Council appointees. It sets out a number of obligations aimed at preventing conflicts between private and public interests and prohibits various actions that could give rise to such conflicts. Ministers and parliamentary secretaries are also subject to the Conflict of Interest Code for Members of the House of Commons. This annual report focuses solely on the 2,461 public office holders who are subject to the Act. All public office holders are subject to the Act’s core set of conflict of interest and post-employment rules. Some, referred to simply as public office holders, are subject only to those general rules. They include part-time members of federal boards, commissions and administrative tribunals, and some part-time ministerial staff. Others, referred to as reporting public office holders, are also subject to the Act’s reporting and public disclosure provisions and its prohibitions against engaging in outside activities and holding controlled assets. They include ministers and parliamentary secretaries, ministerial staff and full-time Governor-in-Council appointees such as deputy ministers, heads of Crown corporations and members of federal boards. Types of public office holders subject to Conflict of Interest Act Ministers and parliamentary secretaries (65)3%Governor-in-Council appointees (481)19%Ministerial staff (566)23%Public office holders without reporting obligations (1,349)55% The Act’s post-employment rules apply to public office holders after they leave public office. Some rules apply to all former public office holders for life, and others apply only to former reporting public office holders during a one- or two-year cooling-off period. Public office holders 2014-20152015-20162016-20172017-2018Public office holders without reporting obligations1,3211,2901,2421,349Reporting public office holders1,1289231,0121,112 Turnover among public office holders Newly appointed public office holders Public office holders who left office Public office holders without reporting obligations414307Reporting public office holders345245 Our achievements Administering the Conflict of Interest Act involves a range of activities. They include informing public office holders about their obligations under the Act immediately upon appointment, providing confidential advice, receiving and reviewing confidential disclosures and public declarations, maintaining a public registry of publicly declarable information, issuing administrative monetary penalties when appropriate, investigating possible contraventions and reporting to Parliament. These and other activities are supported by our Office infrastructure. Our Office has ongoing contact with public office holders starting around the time of their appointment and continuing, in some cases, even after they have left public office. Our Office works closely with public office holders to help them achieve compliance with the Act within 120 days after their appointment, and to help them maintain compliance during and after their terms of office.​ Information given to public office holders​ 2014-20152015-20162016-20172017-2018Information packages for new public office holders and reappointed public office holders589875545937Annual reminder of obligations2,7271,7271,8921,960Information packages on post-employment obligations6521,013446584 The first step is a confidential disclosure of detailed information on assets, liabilities, outside activities and other interests. It must be submitted to our Office no later than 60 days after appointment. Our Office then reviews each confidential disclosure and advises the reporting public office holder of the measures needed to comply with the Act. Compliance measures may include the public disclosure of certain information, the divestment of controlled assets through a blind trust or arm’s-length sale, the establishment of conflict of interest screens, and recusals. Most compliance measures are identified in the public registry, but some are not made public for privacy reasons relating to reporting public office holders’ family members or because they fall within an exception referred to in the Act. By way of illustration, in 2017-2018, our Office established 28 special compliance measures and required 56 reporting public office holders to divest their controlled assets. The initial compliance process is complete when the reporting public office holder signs a statement summarizing the steps he or she has taken to comply with the Act. Reporting public office holders also face a number of ongoing reporting requirements throughout their term of office: They must review their compliance arrangements with advisors from our Office every year and update information previously disclosed to our Office. This is called an annual review.They must inform us of any material change to their circumstances within 30 days of the change.They must publicly declare any acceptable gifts with a value of $200 or more within 30 days after acceptance. They must forfeit any gifts received as an expression of courtesy or protocol valued at $1,000 or more and publicly declare the forfeiture.Ministers and parliamentary secretaries must publicly declare, within 30 days, any travel on non-commercial chartered or private aircraft accepted for themselves, their families or ministerial staff or advisers. They can only accept such travel if required in their capacity as public office holders, in exceptional circumstances or with the prior approval of the Conflict of Interest and Ethics Commissioner.​ The Act establishes deadlines for confidential disclosures and public declarations, and the vast majority of reporting public office holders meet those deadlines. In some cases, deadlines are missed because of delays in our Office being notified of appointments or because of other circumstances beyond the reporting public office holders’ control.​ In cases where public office holders are not meeting their obligations under the Act, I can issue compliance orders to bring them into compliance. In 2017-2018, four compliance orders were issued to require public office holders to return the necessary documents to complete their annual review process. One compliance order was issued to require a public office holder to divest controlled assets. Percentage of new reporting public office holders who missed 60-day filing deadline by one week or more 2009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-20184%7%8%7%3%3%3%5%4% Percentage of new reporting public office holders who missed 120-day filing deadline by one week or more 2009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-20187%2%5%2%3%3%1%15%4% Advice and education Public office holders frequently seek advice from our Office during or after their term of office. In addition to providing public office holders with direction on how to deal with various situations, we issue, update and disseminate a variety of informational materials about the requirements of the Act. We send an annual letter to public office holders who do not have reporting obligations and post detailed information about public office holders’ obligations on our website. We also give presentations to offices and organizations whose members are subject to the Act. In 2017-2018, our Office was asked to give 22 such presentations. Number of instances in which public office holders sought direction and advice 2014-20152015-20162016-20172017-20181,7921,8431,7532,084 Types of direction and advice given to public office holders in 2017-2018 Material changes736General obligations475Gifts439Post-employment obligations270Outside activities164 A greater focus on education Upon taking office, I signalled that education and outreach would be a key focus of my approach in order to help public office holders understand and meet their obligations under the Conflict of Interest Act. We will leverage modern technology to implement education and outreach initiatives. With a greater presence on Twitter, we have already begun making more use of the possibilities this information-sharing platform has to offer. We will make available new options such as webinars and online videos for the information sessions offered to public office holders and Members of Parliament at the start of their terms and during their time in office. By offering methods that accommodate their busy schedules, I am confident that we will be able to reach many more public office holders. Our Office undertakes a range of initiatives aimed at educating and informing other stakeholders and the Canadian public about the conflict of interest regimes and the role of our Office in administering them. It also facilitates my reporting to Parliament and exchanges information with other jurisdictions. We received 3,073 communications from the public and the media in 2017-2018. This represents a 29% increase in volume compared to the previous year. In the interests of transparency, and while guaranteeing that confidentiality requirements will be strictly met, I believe Canadians should receive as much information as possible about what our Office is doing. The media also play a role in promoting awareness of the mandate and activities of our Office. Communications from the public 2014-20152015-20162016-20172017-20185971,3732,0662,662 Requests for information and interviews from the media 2014-20152015-20162016-20172017-2018140143315411 ​Service standards Our Office recognizes the importance of responding to requests for advice or information from public office holders, members of the public and the media in a timely manner, and has established service standards to help us do so. The target for achieving those service standards was set at 75%. Results All stakeholders, including public office holders, were contacted within 3 days of our Office being notified of their appointment 81% of casesRequests from all stakeholders, including public office holders, were dealt with within 3 business days 93% of casesMedia requests were responded to within 3 hours 87% of casesPublic requests were responded to within 2 business days 85% of cases Contacts with Parliament There were six appearances before parliamentary committees in relation to our Office and its work in 2017-2018: House of Commons Standing Committee on Access to Information, Privacy and Ethics, regarding: Main Estimates 2017-2018, May 2, 2017Certificate of nomination of Mario Dion to position of Conflict of Interest and Ethics Commissioner, December 12, 2017The Trudeau Report, January 10, 2018Review of the Conflict of Interest Act, February 8, 2018 House of Commons Standing Committee on Procedure and House Affairs, regarding: Bill C-50 amending the Canada Elections Act (political financing), October 17, 2017 House of Commons Standing Committee on Official Languages, regarding: Air Canada’s implementation of the Official Languages Act, October 17, 2017 Sanctions I can issue administrative monetary penalties for failures to meet certain reporting requirements of the Conflict of Interest Act within the established deadlines, including confidential report filings, disclosures of material changes and firm offers of outside employment, as well as their acceptance, and public declarations of gifts and recusals. Sixteen administrative monetary penalties were imposed on public office holders in 2017-2018. When a penalty is issued, the Act requires that the Commissioner make public the nature of the violation, the name of the public office holder and the amount of the penalty. This has been done to date by means of the public registry on our Office’s website. Effective April 1, 2018, I will enhance the deterrent effect of administrative monetary penalties by announcing on Twitter any penalties imposed under the Act as soon as they are added to the public registry. Number of administrative monetary penalties issued 2014-20152015-20162016-20172017-201810121416 Administrative monetary penalties issued in 2017-2018 Failure to declare a material change9Failure to submit a confidential report within deadline5Incomplete confidential report2 Examinations 44 concerns reviewed5 ongoing examinations on March 31, 20183 examination reports published I can also conduct investigations, called examinations, of possible contraventions of the Act. All examination reports are made public. I can conduct examinations at the request of a Senator or Member of the House of Commons who provides reasonable grounds to believe that the Act has been contravened. I also have the discretion to self-initiate an examination if I have reason to believe the Act has been contravened, based on information that comes to the attention of our Office in various ways, such as media reports and complaints from members of the public. When our Office receives information about a possible contravention of the Act, we open a case file. In each instance, we review the information to determine whether the concern raised falls within the mandate of our Office and, if it does, whether there is reason to believe that a contravention of the Act has occurred. Some of these initial reviews lead to examinations, and in other cases, an examination is not found to be warranted and the files are closed. Concerns reviewed by our Office 2014-20152015-20162016-20172017-2018Case files closed without proceeding to an examination23213136Case files that warranted an examination11978Case files still under consideration at fiscal year end2300 Source of concerns raised Members of general public26Members of the House of Commons13Media articles2Within the Office2Referrals from Public Sector Integrity Commissioner1 Persons who are the subject of concerns raised Current or former minister or parliamentary secretary30Current or former public office holder11Person not subject to the Act3 Nature of concerns raised Furthering a private interest20Preferential treatment10Duty to recuse7Postemployment rules5Insider information4Gifts and other advantages2Public declaration2Private air travel1 In The Toews Report, issued on April 21, 2017, the Honourable Vic Toews, former Minister of Public Safety and Senior Regional Minister for Manitoba, was found to have contravened some of his post-employment obligations under the Act. In one instance, less than two years after leaving public office, Mr. Toews, through a company owned by his spouse, provided consulting services on a number of issues for the Norway House Cree Nation, a group with which he had had direct and significant official dealings, relating to government business, during his last year in public office. As a result, Mr. Toews was found to have contravened subsection 35(1) of the Act. In a second instance, Mr. Toews, when he was President of the Treasury Board in 2007, had approved a transfer of lands. The decision was subsequently challenged in court by several First Nations, including the Peguis First Nation. After leaving public office, Mr. Toews acted on behalf of the Peguis First Nation by providing strategic advice to their legal counsel and by meeting with municipal and provincial officials on the ongoing court matter. In acting for or on behalf of a party that was seeking relief against a decision in which he had been involved as a minister of the Crown, Mr. Toews was found to be in contravention of subsection 34(1). In The Wright Report, issued on May 25, 2017, Mr. Nigel Wright, former Chief of Staff to former Prime Minister Stephen Harper, was found to have contravened two of the Act’s conflict of interest rules while in public office. In providing funds to Senator Mike Duffy so he could pay back over $90,000 in claimed living expenses and managing the issue in the context of his responsibility as Chief of Staff to the Prime Minister, Mr. Wright was in contravention of subsection 6(1) of the Act. By asking if the Conservative Fund Canada could provide funds for the reimbursement, Mr. Wright was in contravention of section 9, which prohibits public office holders from using their position as public office holders to seek to influence others in order to improperly further the private interests of a third party. In The Trudeau Report, issued on December 20, 2017, the Right Honourable Justin Trudeau, Prime Minister of Canada, was found to have contravened the Act in accepting gifts of vacations, including private travel, on behalf of himself and his family, on a private island owned by the Aga Khan, who chairs institutions that have official dealings with the Government of Canada. While Mr. Trudeau and the Aga Khan had a relationship based on a family connection, it could not be considered to be a friendship for the purposes of the Act. As such, the gifts of vacations should not have been accepted as they could reasonably be seen to have been given to influence Mr. Trudeau, resulting in a contravention of section 11 of the Act. Having accepted the gifts of vacations, Mr. Trudeau should have recused himself from any dealings relating to the Aga Khan and his institutions. As a result, Mr. Trudeau was found to have contravened sections 5 and 21. By accepting private air travel to the Aga Khan’s island, Mr. Trudeau was found to have contravened section 12.​ ​Collaboration and best practices Our Office continued to work with counterparts in Canada and other countries in 2017-2018, exchanging information about conflict of interest rules and practices and discussing related issues in order to stay abreast of issues and developments in the field. In September, our Office was represented at the annual meeting of the Canadian Conflict of Interest Network (CCOIN), held in Charlottetown. Created in 1992, CCOIN is made up of conflict of interest commissioners at the federal level and from all Canadian provinces and territories. Our Office has coordinated information-gathering for CCOIN since 2010. In December, members of our Office attended the annual conference of the Council on Governmental Ethics Laws (COGEL), in Toronto. COGEL is a U.S.-based, international not-for-profit organization of government ethics practitioners of which our Office is a member. In March, I signed a memorandum of understanding with the Commissioner of Lobbying to cooperate on education and outreach. Among other activities, we will hold joint information sessions, including webinars, for individuals affected by the work of both offices. As part of our international outreach, we responded to information requests from Australia, Indonesia, Ireland, Kazakhstan, South Korea, the Group of States against Corruption (GRECO) and ParlAmericas. Our tools Strategic plan We have adopted a Strategic Plan for 2018-2021 that sets the course for our Office for the next three years and beyond. It will help guide our priorities and align our activities in light of our increasing workload. (Please refer to Significant Trends bellow.) Our strategic plan, which is published on our Office’s website, identifies three key priorities and the means by which we will achieve them: Build and improve communications and outreach processesModernize technology and information management structuresMaintain operational excellence Progress against our strategic plan will be continually monitored and I will report on it in my future annual reports to Parliament. Brand identity The beginning of my mandate was an ideal time to rethink the brand identity of our Office, which had just entered its second decade, in support of our mission. I also wanted to introduce a modern look and feel while honouring our Office’s existing standards of professionalism.​ My staff and I partnered with a creative firm on the development of a brand identity that I believe offers an effective visual representation of our mission. It communicates the independent and impartial character of our Office, the nature of the work we do and the way we do it—with integrity, rigour and consistency. Branding elements include three complementary combinations of colours and designs that represent various facets of our identity, including our role in helping safeguard the public interest and our forward-looking approach. All feature the Canada Coat of Arms in recognition of my status as an Officer of the House of Commons. Investments in our people I have established a Quality Workplace Promotion Committee whose goal is to promote the well-being of our employees. It will support a healthy workplace and implement initiatives to sensitize our staff on issues affecting the work environment, such as diversity, inclusion, mental health and wellness, professional development, employee and management engagement, and the importance of a respectful workplace.​ Office infrastructure As I noted earlier, the administration of the conflict of interest regimes is supported by the infrastructure of our Office. It has a sound internal management framework in place to ensure the prudent stewardship of public funds, the safeguarding of public assets and the effective, efficient and economical use of resources. Because I am an independent Officer of the House of Commons and our Office is a parliamentary entity, we are not generally subject to legislation governing the administration of the public service or to Treasury Board policies and guidelines. We try to ensure that our resource management practices are, to the greatest extent possible, consistent with those found in the public service and in Parliament. We also look at various policies and practices of other parliamentary entities and generally follow what they do, unless there is a valid reason for our Office to take a different approach. Our Office’s financial statements are audited each year by an independent external auditor and no concerns have been raised. A Financial Resources Summary appended to this report outlines our financial information for the 2017-2018 fiscal year. In support of our strategic objective of modernizing technology and information management structures, in 2017-2018 we replaced our financial management system and started working to upgrade our electronic case management system. We continued to make our operations more efficient in 2017-2018 by implementing a paperless office initiative and expanding our use of a document management system that had been piloted as a replacement of our Office’s shared electronic drive.​ Commissioner's Office 4 positions Advisory and Compliance 18 positions Investigations and Legal Services 8 positions Communications, Outreach and Planning 8 positions Corporate Management 11 positions Our challenges and opportunities​ Although it is always difficult to predict with any accuracy what important changes will occur that will affect the operations of our Office, I believe it is nimble enough to reallocate its resources to meet emerging long-term trends. At this moment, we observe a marked increase in relation to four distinct areas of our operations, as discussed earlier. It is also possible that other things will happen that we are not in a position to predict at this time. Significant trends Our Office is facing several trends that have contributed to a significant increase in our workload. We have received a growing number of requests for advice from public office holders, including requests for advice about the acceptability of gifts. While dealing with more requests takes more resources, this trend is indicative, I believe, of a desire on the part of public office holders to take steps to comply with the Conflict of Interest Act.​ Transactions with public office holders 2014-20152015-20162016-20172017-2018Advice sought by public office holders1,7921,8431,7532,084Initial compliance completed306374585380Communications sent by our Office3,4243,6152,8833,481Public registry postings7079571,099953 Requests for advice from public office holders 2008-20092009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-20185861,5061,6001,5501,7481,7311,7921,8431,7532,084 I intend to review our guidelines affecting a number of areas, such as gifts, in order to simplify them as much as possible. Instances of advice and direction relating to gifts (Data on requests relating to gifts is only available as of 2010-2011) 2010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-2018200160188231209168401439 There has also been an increase in the number of communications from members of the public and requests for information or interviews from the media. Communications from the public 2008-20092009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-20184295815445938391,0975971,3732,0662,662 Requests for information from the media 2008-20092009-20102010-20112011-20122012-20132013-20142014-20152015-20162016-20172017-2018281744102185213140143315411 677 media mentions of Office18,960 tweets mentioning OfficeOffice was mentioned in 68% of Question Periods in House of Commons Providing consistent advice When public office holders seek advice from our Office on how to comply with the Conflict of Interest Act, it is important that the advice they receive be clear and consistent. I recognize that there is no one-size-fits-all approach that can apply to every situation or even, in some cases, to situations that may appear similar, and that the advice provided by our Office must take into account the specific circumstances of individual public office holders. I acknowledge, however, the importance of ensuring consistency, in order to reduce uncertainty and confusion, and to ensure that public office holders feel confident the advice they receive is fair and appropriate. Fairness also requires that different public office holders in the same situation receive the same advice over time. One way I hope to address this challenge is by continuing to develop internal tools to record my interpretations of the Act and make them accessible to employees of our Office. I will also maintain an ongoing dialogue with those staff members who provide advice to public office holders. One of my key roles as Commissioner is to interpret the Act. Over the coming months, our Office will review all of the informational materials that have been published on our website for the guidance of public office holders, in order to ensure that they adequately reflect current interpretations of various aspects of the Act. Conducting examinations with due dispatch I recognize that, when our Office conducts an examination, the current or former public office holder who is the subject of the examination may experience uncertainty and concern. This is particularly true in cases where the identity of the individual is public knowledge, as this can lead to speculation and possible reputational damage, even when the individual is eventually found not to have contravened the Conflict of Interest Act.​ I will ensure that our Office conducts examinations with due dispatch while still conducting them thoroughly, with proper diligence and being careful to respect procedural fairness. Better targeting education and outreach The individuals subject to the Conflict of Interest Act do not constitute a homogenous group. In fact, there are three distinct groups of public office holders: ministers and parliamentary secretaries, ministerial staff and Governor-in-Council appointees. The types of work, experiences, levels of responsibility and degrees of influence vary greatly among these groups, which include senior ministers as well as summer students. Because of their diversity, our Office must adapt its outreach and communications tools to the particular characteristics and needs of each group, in order to ensure they are as effective as possible. As mentioned earlier, we are also moving away from a traditional “classroom” approach. In 2018-2019, we will develop webinars, online videos and other products using new media in order to inform and educate public office holders about their obligations under the Act. Operating within a static budget I am impressed by the fact that even though our Office’s workload has increased substantially in its almost eleven years of operation and we have faced higher technology costs and other inflationary pressures, our Office has maintained an annual operating budget that is no higher today than it was in its first full year of operation. In its earlier years, our Office had relatively low expenditures compared with its allotted budget, which gave it room to build an effective organization. However, our Office today has little flexibility with which to meet unforeseen demands, such as a marked increase in investigation requests. Although we remain committed to using our resources effectively, efficiently and economically, it does not appear that meeting the growing demands on our Office at current funding levels will be possible over the course of my seven-year mandate. Maximizing transparency I am committed to making our Office and its work as transparent as possible. This is a challenge because of the strict confidentiality requirements set out in the Conflict of Interest Act, particularly regarding examinations and advice provided to public office holders. There may also be other valid reasons in some cases for not divulging information even when we are permitted to do so. For example, I have chosen not to identify the subjects of several ongoing examinations at this time in order to safeguard their privacy against the possibility of undue reputational damage. If those examinations proceed, we will report publicly on the findings. While respecting these constraints and other considerations, we will be as forthcoming with Parliament, the media and the public as we are permitted to be under the Act. Appendix Financial resources summary (thousands of dollars) Program Activity 2017-2018 Actual Spending 2018-2019 Alignment toGovernment of CanadaOutcomes 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 5,973 6,134 6,134 5,827 Government AffairsContributions to employee benefit plans665734734691 ​Total spending6,6386,8686,8686,518 Plus: cost of services received without charge1,148n/an/a1,110 Net cost of department 7,7866,8686,8687,628 The budget process for the Office of the Conflict of Interest and Ethics Commissioner is established in the Parliament of Canada Act. The Speaker of the House considers the estimates for the Office and transmits them to the President of the Treasury Board for inclusion in the estimates of the Government of Canada. The Standing Committee on Access to Information, Privacy and Ethics has within its mandate the role to review and report on the effectiveness, management and operations together with the operational and expenditure plans relating to the Office. Complete audited financial statements appear on our website.

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. The 2016-2017 annual report by former Commissioner Mary Dawson was tabled on June 9, 2017 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2016-2017 annual report by former Commissioner Mary Dawson was tabled on June 8, 2017 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2015-2016 annual report by former Commissioner Mary Dawson was tabled on June 14, 2016 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2015-2016 annual report by former Commissioner Mary Dawson was tabled on June 14, 2016 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2014-2015 annual report by former Commissioner Mary Dawson was tabled on June 9, 2015 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2014-2015 annual report by former Commissioner Mary Dawson was tabled on June 9, 2015 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2013-2014 annual report by former Commissioner Mary Dawson was tabled on June 5, 2014 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2013-2014 annual report by former Commissioner Mary Dawson was tabled on June 5, 2014 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2012-2013 annual report by former Commissioner Mary Dawson was tabled on June 12, 2013 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2012-2013 annual report by former Commissioner Mary Dawson was tabled on June 12, 2013 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2011-2012 annual report by former Commissioner Mary Dawson was tabled on June 21, 2012 in the House of Commons as required by section 90 of the Parliament of Canada Act.

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. The 2011-2012 annual report by former Commissioner Mary Dawson was tabled on June 21, 2012 in the House of Commons as required by section 90 of the Parliament of Canada Act.