Annex A
PWGSC Management Action Plan
Chapter 4: Management of Conflict of Interest
Fall 2010 Report of the Auditor General of Canada

Recommendation

Departmental Response / Comments

OPI/OSI

Action Plan

Target Date

Paragraph 64

AAFC, HRSDC, Canadian Heritage, PWGSC and NRCan should develop an approach to risk assessment that includes identification and prioritization of risks, assessments and mitigation strategies, and residual risk assessment, in the key areas where major conflicts of interest could arise.

Public Works and Government Services Canada accepts the recommendation. The Department has developed a robust approach to risk assessment that includes identification and prioritization of risks; assessments and mitigation strategies; and residual risk assessment. The Department’s Draft Operational Risk Profile will be finalized by the end of December 2010 and it will pay special attention to risks relating to conflict of interest. The Department will use the Operational Risk Profile to refresh its corporate, branch and regional risk profiles. In addition, PWGSC will revise the risk categories annex of it’s Policy on Integrated Risk Management to include conflict of interest risks. It will include these risks in the PWGSC Risk Management Guide, as well as the training courses for PWGSC executives (half-day training session) and for managers and supervisors (1-day session).

OPI: Frank Brunetta, Assistant Deputy Minister, Departmental Oversight Branch

ORP

The Department is currently in the process of finalizing the Operational Risk Profile (ORP). Conflict of interest risks were discussed and risks response strategies were developed. The various workshops with stakeholders to validate risk statements and develop appropriate risk strategies are near completion.

The ORP will be submitted to the Deputy Minister’s Management Committee (DMMC) for final approval.

Once the ORP has been approved by the Deputy Minister Management Committee, the Department will proceed to refresh the Corporate, Branch and Regional risk profiles.

IRM POLICY

The Department is in the final stages of approval for the Integrated Risk Management Policy. The policy addresses COI risks.

Once the policy is promulgated, the strategy to implement the policy will be launched. Deliverables include:

The release of the Risk Management Guide.
A training blitz for executives and staff has been launched and will continue into next fiscal year.

November 30, 2010

December 31, 2010

March 2011

December 31, 2010

February 2011

Ongoing

Recommendation	Departmental Response / Comments	OPI/OSI	Action Plan	Target Date
Paragraph 65 Once they have identified high-risk areas through an appropriate risk assessment process, AAFC, HRSDC, Canadian Heritage, PWGSC, and NRCan should require public servants in identified high-risk areas to report regularly whether or not they have a conflict of interest.	Public Works and Government Services Canada accepts the recommendation. Once, PWGSC has identified its areas at high risk for conflict of interest, the department will implement a process whereby public servants occupying positions in those high risk areas will be required to attest, at an interval appropriate to the risk exposure, that they understand their obligations under the Values and Ethics Code for the Public Service and indicate whether or not they need to submit or update their confidential declaration.	OPI: Diane Lorenzato, Assistant Deputy Minister, Human Resources Branch	The Department will implement a process whereby public servants occupying positions in high risk areas will be required to attest that they understand their obligations under the Values and Ethics Code and indicate whether or not they need to submit or update their confidential declaration. The mechanism will be determined once the risk assessment is completed.	March 31, 2011 – To determine mechanism. June 30, 2011 – To implement
Paragraph 72 HRSDC, Canadian Heritage, PWGSC and NRCan should ensure their training is based on the conflict of interest risk that staff in specific areas face as they carry out their duties, and the training should include cases and scenarios in these areas.	Public Works and Government Services Canada accepts this recommendation. The Department is offering training that includes cases and scenarios developed and geared directly towards certain risks identified within a particular area of PWGSC’s operations. For example the training provided to Parliamentary Precinct Branch employees in May and June 2009 included scenarios for discussion geared to the types of contracting conducted within the branch. Similar training based on identified risks was also delivered within other areas of the Department in November 2009 and March 2010. Once the risks in key areas where major conflicts of interest could arise have been identified and prioritized, PWGSC will review its training program to ensure the program is based on the conflict of interest risks that staff in specific areas could face as they carry out their duties. The Department will also ensure that its updated training program includes relevant cases and scenarios where appropriate.	OPI: Diane Lorenzato, Assistant Deputy Minister, Human Resources Branch	The Department is currently offering training that includes cases and scenarios geared towards certain risks identified within a particular area of PWGSC’s operations. Once risks in key areas where conflict of interest could arise have been identified and prioritized, PWGSC will review its training program to ensure it is based on conflicts of interest risk that staff in specific areas could face.	June 30, 2011

Recommendation

Departmental Response / Comments

OPI/OSI

Action Plan

Target Date

Paragraph 65

Once they have identified high-risk areas through an appropriate risk assessment process, AAFC, HRSDC, Canadian Heritage, PWGSC, and NRCan should require public servants in identified high-risk areas to report regularly whether or not they have a conflict of interest.

Public Works and Government Services Canada accepts the recommendation. Once, PWGSC has identified its areas at high risk for conflict of interest, the department will implement a process whereby public servants occupying positions in those high risk areas will be required to attest, at an interval appropriate to the risk exposure, that they understand their obligations under the Values and Ethics Code for the Public Service and indicate whether or not they need to submit or update their confidential declaration.

OPI: Diane Lorenzato, Assistant Deputy Minister, Human Resources Branch

The Department will implement a process whereby public servants occupying positions in high risk areas will be required to attest that they understand their obligations under the Values and Ethics Code and indicate whether or not they need to submit or update their confidential declaration.

The mechanism will be determined once the risk assessment is completed.

March 31, 2011 – To determine mechanism.

June 30, 2011 – To implement

Paragraph 72

HRSDC, Canadian Heritage, PWGSC and NRCan should ensure their training is based on the conflict of interest risk that staff in specific areas face as they carry out their duties, and the training should include cases and scenarios in these areas.

Public Works and Government Services Canada accepts this recommendation. The Department is offering training that includes cases and scenarios developed and geared directly towards certain risks identified within a particular area of PWGSC’s operations. For example the training provided to Parliamentary Precinct Branch employees in May and June 2009 included scenarios for discussion geared to the types of contracting conducted within the branch. Similar training based on identified risks was also delivered within other areas of the Department in November 2009 and March 2010. Once the risks in key areas where major conflicts of interest could arise have been identified and prioritized, PWGSC will review its training program to ensure the program is based on the conflict of interest risks that staff in specific areas could face as they carry out their duties. The Department will also ensure that its updated training program includes relevant cases and scenarios where appropriate.

OPI: Diane Lorenzato, Assistant Deputy Minister, Human Resources Branch

The Department is currently offering training that includes cases and scenarios geared towards certain risks identified within a particular area of PWGSC’s operations. Once risks in key areas where conflict of interest could arise have been identified and prioritized, PWGSC will review its training program to ensure it is based on conflicts of interest risk that staff in specific areas could face.