Para #

Recommendation

Department’s  Response

Deliverables
(How are we going to do this?)

Proposed Timelines

6.28

NRCan should develop policies and guidance to identify and address conflict of interest situations noted by our audit.

Agreed. NRCan respects and adheres to the Values and Ethics Code for the Public Service and the Treasury Board of Canada Policy on Transfer Payments. It acknowledges that, in this isolated case, certain departmental officials failed to identify the potential for conflicting interests with possible advantages for private sector recipients. When this error was brought to the attention of senior management, numerous corrective actions were taken, including the four action areas identified in paragraph 6.25 of this report. NRCan will continue to develop new guidance and procedures to assist staff in preventing conflict of interest situations involving contribution agreements. Some new measures currently under development will be introduced in 2009.

NRCan:

1. The department implemented a Centre of Expertise and a Transfer Payment Review Committee.  The department established a Center of Expertise for Values and Ethics and identified a Values and Ethics Champion at the ADM level.  As part of the training provided to employees managing grant and contribution programs, the department holds employee engagement sessions with case studies addressing Values and Ethics and Conflict of Interest situations and appropriate responses.



2. Updated the Department’s Policy and Directives to identify and address Conflict of Interest situations.



3. The Centre of Expertise developed a Contribution Agreement Quality Assurance Checklist to be used by grant and contribution managers.



4. Added three Conflict of Interest clauses to its contribution agreements to avoid Conflict of Interest situations involving employees and recipients.



5. Incorporated Conflict of Interest requirements into transfer payment training provided to employees managing grant and contribution programs.



6. NRCan is compliant with the Treasury Board Secretariat Transfer Payment policy and directive.

Completed

Completed

Completed

Completed

Completed and ongoing

Completed

Para #

Recommendation

Department’s  Response

Deliverables
(How are we going to do this?)

Proposed Timelines

6.29

NRCan should ensure that the management of contribution agreements, and compliance with them by both parties to the agreement, is monitored independently from outside the program area

Agreed. NRCan is committed to full compliance and improved management regarding all of its contribution agreements. As noted in this report, upon the advice of its internal auditors in 2006, NRCan promptly implemented a series of measures to improve the management and controls surrounding its contribution agreements. Another important measure was the creation of the Centre of Excellence, outside of the program areas, to provide advice and guidance on contribution agreements. In addition, senior management initiated a full review of the five agreements subsequently examined by the OAG to ensure and confirm that every dollar spent was for work of value. This review, completed in 2007, confirmed that work of value was completed and that no money was lost. The Department further recognizes and supports the OAG recommendation that the remaining step to improving the management, monitoring, and reporting of contribution agreements is the requirement for independent monitoring from outside the program area. NRCan is developing and will implement a regime for independent monitoring of its contribution agreements.

NRCan:

1. Implemented a Centre of Expertise in September 2006 and a Transfer Payment Review Committee at the Assistant Deputy Minister level in October 2006.  The Center of Expertise reviews all grant and contribution agreements over $100K, and also promotes best practices and trains employees managing grant and contribution programs.  The Transfer Payment Review Committee reviews all grant and contribution agreements over  $1 M and any high risk agreements over $100K identified and referred by the Center of Expertise.



2. Implemented a 20-point Risk Assessment and Conflict of Interest Checklist across the department.

Completed

Completed