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. A review of the Values and
Ethics Policy Centre activities has been completed. Service standards are
being developed. In October 2010, the service standards will be communicated
to employees, and performance against the standards will be tracked from that
date. |
Service standards developed:
The Values and Ethics Policy Centre (VEPC)
completed a review of its service standards.
The following three standards have been
updated and revised to ensure consistency with other Human Resources Branch
service standards:
- Conflict of Interest (COI) Assessment of Interchange Canada
Program Agreements (ten (10) working days);
- COI Assessment of offers of third party funded travel (four (4) weeks);
and
- Political Activities Messages to Employees (two (2) working days
following notice from the Public Service Commission).
The VEPC has also established new service
standards for the following:
- Assessment for a formal COI disclosure (one (1) month, complex
cases: up to 90 days); and
- Response to NIL Confidential Reports (ten (10) working days)
The service standards include timeframes
for acknowledgements of receipt and account for the possibility of temporary
mitigating measures to be taken to eliminate, alleviate or minimize existing
risks associated with a disclosed activity, asset or liability while the
assessment is underway.
Service standards communicated to
employees:
Service Standards are posted on the
internal AAFC- Values and Ethics Website along with other information for
employees regarding their obligations to avoid conflict of interest.
Performance monitoring
Monitoring adherence to the service
standards has begun using the existing case tracking mechanisms. Performance
will be reported regularly to the ADM, HR, as part of established quarterly performance
monitoring. |
Completed
Completed
Incorporated in the quarterly reports by March 31, 2011. |
ADM, Human
Resources |
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. The Department has completed a
risk assessment for conflict of interest for 2010. It will use lessons
learned from this process, along with any direction and guidance from the
Treasury Board of Canada Secretariat on assessing conflict of interest risk,
in future assessments. |
Conflict of interest risk assessments
Building on the department-wide conflict
of interest risk assessment, Research Branch and the Centre for Program
Excellence (COPE) have led a more detailed risk assessment of collaborative
agreements between AAFC and outside stakeholders. Of the eight (8) risk
areas considered, six (6) are explicitly related to conflict of interest, but
none of the identified risks were found to have a high residual risk
given the controls already in place, including training and guidance for
employees. Results were presented to the Departmental Audit Committee in
November 2010. HR Branch is continuing to work with other branches to ensure
that conflict of interest risk controls are adequate and up-to-date.
Mitigating strategies
The forthcoming organizational Code of Conduct for AAFC will include additional measures to address specific identified conflict of interest risk
areas, including employees serving on external boards of directors, employees
receiving offers of travel from a third party, and employees
with assets or outside activities related to AAFC’s mandate.
Performance measurement and future
assessment
AAFC will measure
performance under the new Code and use that information to determine where
additional conflict of interest risk assessments and/or mitigation may be
necessary. |
Completed
The Code of Conduct for AAFC will be implemented further to the establishment of the Values and Ethics Code for the
Public Sector, expected in Spring 2011.
AAFC will seek to
develop outcome-based measures for values and ethics in 2011-12, further to
the requirements of the new AAFC Code. |
Human Resources (for conflict of interest
risk assessment only; the Office of Audit and Evaluation has overall
responsibility for departmental risk assessment) |
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. Once the Department has identified
its areas at high risk for conflict of interest, it will implement a process
where public servants occupying high risk positions in those areas attest
regularly 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 Report. Phased implementation will begin in
April 2011 in conjunction with the implementation of the new Values and
Ethics Code for the Public Service. |
Regular reporting in identified
high-risk areas
AAFC has already
identified its Grants and Contributions programs as having an elevated risk
of conflict of interest. Accordingly, AAFC is working with the Centre of
Program Excellence (COPE) in the Farm Financial Programs Branch to
incorporate conflict of interest attestations into the steps of the
management processes related to these grants and contributions.
In addition, AAFC will introduce a new
organizational Code of Conduct for AAFC in Spring 2011, coordinating with the
new Values and Ethics Code for the Public Sector. As part of the
implementation of its organizational Code, AAFC is planning to introduce its
own clearer and user-friendly Confidential Report form.
AAFC is also planning an electronic
prompt for employees to attest regularly that they understand their conflict
of interest obligations. |
April 2011.
Expected in Spring 2011 (simultaneous
with the new codes of conduct).
Development and testing by June 2011,
with initial implementation to follow. |
Human Resources |