4.51  Agriculture and Agri-Food Canada, Canadian Heritage, Human Resources and Skills Development Canada, and Natural Resources Canada should put in place standards to ensure that conflict of interest declarations are addressed in a timely fashion, and that public servants take the required action to eliminate or reduce the conflict of interest.

Agreed. The Department has recently launched a Values and Ethics Program Framework built around five pillars: leadership, outreach, policies and procedures, guidance and advice, and oversight. This framework, along with the Department’s Corporate Risk Framework, is providing policy guidance, context, and coordination for departmental priorities and action related to conflicts of interest, including the management response to this audit.

Consistent with the five pillars, the Department regularly advises on declaration obligations, most recently on 29 June 2010, and will continue to do so on an annual basis. The Department will also be establishing service standards to ensure that such declarations are addressed on a timely basis, with a target date of 31 December 2010 for establishing these service standards.

* V&E Centre of Expertise: Composed of the Labour Relations, Values and Ethics unit and the NRCan V&E Champion – ADM and Chief Scientist, Geoff Munro.

4.64  Agriculture and Agri-Food Canada, Canadian Heritage, Human Resources and Skills Development Canada, Natural Resources Canada, and Public Works and Government Services Canada should develop an approach to risk assessment that includes identification and prioritization of risks, assessment and mitigation strategies, and residual risk assessment, in the key areas where major conflicts of interest could arise.

Agreed. As noted in this report, the Department has taken steps to assess risks for conflict of interest. It has launched a corporate risk profile, which is a departmental risk assessment process, to identify, assess, and prioritize corporate-level risks and mitigation strategies. This will include but is not limited to conflict of interest. The corporate risk profile clarifies governance and accountabilities, and fosters employee engagement, training, and risk awareness. The Department will build on this work to more fully and systematically assess potential risk areas.

Specifically, through the Values and Ethics Program Framework and its corporate risk profile, the Department has identified its transfer payment (grant and contribution) programs as the highest conflict of interest risk area. The Department has established a Centre of Expertise in the Human Resources Branch for Values and Ethics and identified a Values and Ethics Champion at the assistant deputy minister level. The Department’s Values and Ethics Champion, managers, and the Centre of Expertise provide advice and guidance to eliminate or reduce conflict of interest. Additionally, the Department added three conflict of interest clauses to its contribution agreements to avoid conflict of interest situations involving employees and recipients.

The second conflict of interest priority risk area for the Department is Science and Technology (S&T). An S&T Conflict of Interest Working Group was created and mandated through established terms of reference to focus its efforts in assessing the Department’s needs, elaborate relevant working tools, and provide direction on S&T collaboration. Working Group recommendations will be fully implemented by the end of the 2010–11 fiscal year.

The third conflict of interest priority area for the Department is contracting and human resources services. By 31 March 2011, the Department will establish guidelines regarding the hiring of former public servants.

* V&E Centre of Expertise: Composed of the Labour Relations, Values and Ethics unit and the NRCan V&E Champion – ADM and Chief Scientist, Geoff Munro.
** COI Working Group on S&T Collaboration: Co-chaired by representatives of the Chief Scientist and the Labour Relations, Values and Ethics unit, through consultation and engagement of departmental science leaders and labour groups.  The Group addresses S&T COI high-risk areas in order of priority through various tools including decision trees, illustrative guidelines, training seminars and online reference materials.
*** G&C Centre of Expertise: Supports effective management of grant and contribution programs in NRCan, while ensuring that NRCan maintains an efficient and accountable Grants & Contributions (G&C) management framework.  The G&C Centre of Expertise is a section within the Financial Projects Division, Financial Management Branch.

4.65  Once they have identified high-risk areas through an appropriate risk assessment process, Agriculture and Agri-Food Canada, Canadian Heritage, Human Resources and Skills Development Canada, Natural Resources Canada, and Public Works and Government Services Canada should require public servants in identified high-risk areas to report regularly, whether or not they have a conflict of interest.

Agreed. The Department’s Values and Ethics Program Framework includes the implementation in 2010–11 of a process where public servants in high risk positions attest regularly as to whether they are in a situation that could present a conflict of interest. As per the Values and Ethics Code for the Public Service, employees faced with conflict of interest situations are required to submit a confidential report, which is then assessed by the Department’s Values and Ethics Centre of Expertise. As appropriate, an action plan is developed and implemented to mitigate risks.

* V&E Centre of Expertise: Composed of the Labour Relations, Values and Ethics unit and the NRCan V&E Champion – ADM and Chief Scientist, Geoff Munro.
** COI Working Group on S&T Collaboration: Co-chaired by representatives of the Chief Scientist and the Labour Relations, Values and Ethics unit, through consultation and engagement of departmental science leaders and labour groups.  The Group addresses S&T COI high-risk areas in order of priority through various tools including decision trees, illustrative guidelines, training seminars and online reference materials.
*** G&C Centre of Expertise: Supports effective management of grant and contribution programs in NRCan, while ensuring that NRCan maintains an efficient and accountable Grants & Contributions (G&C) management framework.  The G&C Centre of Expertise is a section within the Financial Projects Division, Financial Management Branch.

4.72  Canadian Heritage, Human Resources and Skills Development Canada, Natural Resources Canada, and Public Works and Government Services Canada should ensure that their training is based on the conflict of interest risks that staff in specific areas face as they carry out their duties; the training should include case studies and scenarios in these areas.

Agreed. The Department’s Values and Ethics Program Framework includes conflict of interest employee training. The Department has achieved increasing levels of values and ethics awareness and understanding among managers and employees across the Department. For example, it holds employee engagement sessions, including case studies that address values and ethics as well as conflict of interest situations and appropriate responses. These case studies are and will continue to be updated to ensure they reflect realistic and specific situations related to risks that may be encountered.

The Department’s key values and ethics activities planned for the 2010–11 fiscal year include the following:

• leadership and employee engagement;
• outreach and partnering with the Department’s communities of practice and with social media technologies, developing a departmental code of conduct;
• policies, procedures, and processes to address the Department’s needs (for example, establish service standards to address conflict of interest issues);
• guidance and advice to ensure awareness of and conformity to the values and ethics code (guidelines for gifts, hospitality, and other benefits); and
• oversight (monitoring and evaluation) of the values and ethics program’s effectiveness and efficiency (for example, assessing the Department’s ethical climate through an internal survey).

* V&E Centre of Expertise: Composed of the Labour Relations, Values and Ethics unit and the NRCan V&E Champion – ADM and Chief Scientist, Geoff Munro.