Public Works and Government Services Canada Code of Conduct

A Message from the Deputy Minister and Associate Deputy Minister

Dear Colleagues,

Every day, we employees at Public Works and Government Services Canada (PWGSC) are guided by our shared values of respect, integrity, excellence and leadership, and demonstrate our dedication to providing the best service possible to our clients. As the primary common service provider to the Government of Canada, we are accountable to other federal departments and to the Canadian public. This accountability is what inspires the strong foundation of personal and professional integrity with which we work, and motivates the culture of performance excellence we have established as a department.

Our success depends not only on aiming for the highest standards in service and results, but achieving these with integrity each and every day.

While PWGSC demonstrates an existing culture of personal and professional integrity and maintains a daily commitment to ethical behaviour in all its business practices, this present Code of Conduct has been developed in fulfillment of the legislative requirement under the Public Service Disclosure Protection Act (PSDPA).

With over 100 federal departments, agencies and boards as our clients, not to mention the Canadian public, PWGSC has a unique responsibility. Whether through purchasing, banking, real estate or any of our core activities, our commitment to the Client Service Strategy and sound stewardship is at the heart of our mandate. We must ensure the integrity of our processes and decisions as well as set standards for major initiatives such as the greening of government operations.

The Code of Conduct incorporates our responsibilities under the Values and Ethics Code for the Public Sector (VECPS), our PWGSC Statement of Values and guiding principles, and Standards of Conduct consistent with our culture and our unique roles and duties. The Code is a complement to the department's People Management Philosophy and Our Commitments, to be used not only to guide how we work and interact with each other, but also to guide how we make decisions and do business every day.

The Code of Conduct is intended to serve as a compass and points us in the right direction as we seek to incorporate high standards, values and integrity into our everyday actions and decisions. By living our values and working in accordance with our Code of Conduct, not only do we continue to foster a positive workplace, we also demonstrate to our clients and Canadians as a whole that we are worthy of their confidence and trust.

This departmental Code of Conduct comprises three chapters. The first chapter contains the Values and Ethics Code for the Public Sector, which is the primary foundation piece of the PWGSC Code of Conduct, found in Chapter 2. Chapter 3 contains the PWGSC Statement on Conflict of Interest and Post-Employment. We look forward to implementing this new Code of Conduct along with you, as we deliver high-quality services and programs that meet the needs of federal organizations and ensure sound stewardship on behalf of all Canadians.

Chapter 1: Values and Ethics Code for the Public Sector

Please consult the Values and Ethics Code for the Public Sector available on the Treasury Board of Canada Secretariat website. The Public Service Disclosure Protection Act has been in place since 2007 and is considered part of the Federal Accountability Act (FAA) implementation. Section 5 of the PSDPA requires the Treasury Board to establish a general code of conduct to apply to the entire public sector, including Crown corporations and separate agencies.

The appendix of the VECPS includes the duties and obligations of public servants.

Chapter 2: PWGSC Code of Conduct

The PWGSC Code of Conduct includes the Values and Ethics Code for the Public Sector, the PWGSC Statement of Values and guiding principles, the Standards of Conduct and the PWGSC Statement on Conflict of Interest and Post-Employment.

Objective

The PWGSC Code of Conduct provides us all with guidance on our conduct in the context of our position as employees of PWGSC. This Code complements the Values and Ethics Code for the Public Sector and serves as a guide to decision-making and conduct in situations that arise from PWGSC's Mission and Vision and specific responsibilities.

It is an overview of the high standards of behaviour to which we hold ourselves accountable, and demonstrates to our colleagues, suppliers, partners, clients and the public the key principles we are committed to upholding as we discharge our responsibilities to Canadians. Our Code embodies the qualities and behaviours we value in ourselves and in our organization.

Application

The Code of Conduct applies to all PWGSC employees, regardless of level, position or geographic location, and to those working on our behalf, as applicable. The Code does not replace or in any way change PWGSC's policies, business practices or collective agreements.

Acceptance and adherence to this Code is a condition of employment for every PWGSC employee.

A breach of the Code may result in disciplinary measures, up to and including termination of employment. Under the authority of the Financial Administration Act (FAA), PWGSC's Deputy Head has the authority to establish standards of discipline and set penalties. PWGSC's Directive on Discipline provides useful information on the department's expectations as well as processes related to disciplinary measures.

PWGSC Statement of Values

In providing common, central and shared government services, we, the employees of Public Works and Government Services Canada, are guided by and proudly identify with the following values:

  • Respect — We are honest, equitable, fair and respectful with our colleagues, partners and clients, all while recognizing their individual contributions and diversity.
  • Integrity — We act with integrity and in the public's best interest at all times and ensure transparent, accountable and responsible management at all levels of the organization.
  • Excellence — We work collaboratively to provide for excellence and professionalism in the delivery of services to our partners, clients and Canadians while achieving best value for government.
  • Leadership — We demonstrate leadership through responsible action, forward-looking perspective and commitment to continuous improvement.

PWGSC People Management Philosophy and Our Commitments

As an organization, PWGSC strives to give all its employees opportunities to achieve organizational, professional and personal goals in a respectful and inclusive workplace, mobilized and supported by leadership at all levels. We value our integrity and our service-oriented culture as well as our innovative contributions to excellence in government operations by contributing to our commitments in our day-to-day activities.

Standards of Conduct

As employees of PWGSC, we observe and promote the highest standards of conduct, consistent with our PWGSC Statement of Values and guiding principles, duties and responsibilities, and in support of our Mission.

We are committed to the following standards of conduct:

  • We act at all times in full compliance with both the letter and the spirit of all applicable laws.
  • We are committed to prudent and responsible stewardship through adherence to the highest standards of sound financial management.
  • We do not knowingly place ourselves in situations of real, potential or apparent conflict of interest. Accordingly, we disclose when considering or engaged in outside employment and/or ownership of our own business. We comply with guidelines related to gifts, hospitality and other benefits.
  • We protect and safeguard confidential and personal information, and use it only for the purposes for which it was originally collected or created.
  • We ensure the proper management of procurement activities through compliance with all applicable practices, controls and policies.
  • We account for and protect government property and other valuables that we possess or manage, and use government-owned or -leased property or valuables for authorized business purposes. We respect policies and guidelines regarding government computer systems and electronic networks.
  • We deliver effective services to clients and strive for excellence and continuous improvement in the quality of our services and programs—to enhance client satisfaction and provide the best possible value to Canadians.
  • We recognize that in our role as public servants, we owe a duty of loyalty to the Government of Canada. As such, we ensure that our public statements and our actions—including our off-duty conduct—support our ability to carry out our duties; preserve our impartiality and objectivity in the execution of our duties; and reflect positively on our organization.
  • We create and maintain accurate, reliable and usable records in support of ongoing business and we protect the integrity of those records.
  • We observe at all times health, safety and security rules and procedures, and promptly report any actual or potential work-related hazard, accident or injury.
  • We adopt at all times appropriate, reasonable and respectful dress, behaviour and language that reflect the professional image of the department and Canada's public service.
  • We adhere to the principles of merit, non-partisanship, fairness, transparency, access and representativeness in our staffing processes.
  • We do not engage in any discriminatory practices and support at all times a workplace free from harassment and violence.
  • We protect the professional reputation of PWGSC employees and the integrity of PWGSC operations by reporting any suspicion of work-related wrongdoing to management and/or other appropriate authorities. We do so in good faith and, as embodied in the Public Service Disclosure Protection Act, do so without fear of reprisal.

References

Acts and Regulations

Treasury Board of Canada Secretariat Publications

PWGSC Publications

Chapter 3: PWGSC Statement on Conflict of Interest and Post-Employment

CONTEXT

All employees of Public Works and Government Services Canada must, as a condition of their employment, observe the Values and Ethics Code for the Public Sector, the Treasury Board of Canada Secretariat conflict of interest policy, as well as any additional measures instituted by PWGSC within this ministerial Code, and make such declaration as is appropriate in their situation.

Each employee is responsible for taking such action as is necessary to prevent real, potential or apparent conflicts of interest. Employees are also required to observe any specific conduct requirements or conflict of interest guidelines applicable to their branch or agency.

PURPOSE

The purpose of this departmental Statement on Conflict of Interest and Post-Employment is to enhance and maintain public confidence in the integrity of employees of PWGSC by:

  1. informing employees of the public service values and the measures required to comply with the Values and Ethics Code for the Public Sector and the additional PWGSC measures that have been put in place;
  2. minimizing the possibility of conflicts of interest arising between the private interests and the public service duties of employees, and providing for their resolution in the public interest should they arise; and
  3. minimizing the real or perceived possibility of former employees:
    1. receiving preferential treatment or privileged access to government after leaving public office;
    2. taking personal advantage of information obtained in the course of official duties before it has become available to the general public; and
    3. using public office to unfair advantage in obtaining outside employment.

SCOPE

This departmental statement applies to all employees of Public Works and Government Services Canada, including employees on periods of approved leave with or without pay, on interchange agreements within or outside PWGSC, casual employees and students.

DEFINITIONS

Conflict of Interest (Conflit d'intérêts): refers to a situation in which an individual has other competing financial, professional or personal obligations or interests that could interfere, or be perceived to interfere, with his or her ability to adequately perform required duties in a fair and objective manner.

Assets (Biens): items of ownership of a person or business convertible into cash. Assets include but are not limited to real estate and real property, publicly traded securities, self–administered savings plans, stocks and bonds, shares or interests in businesses, including family-owned businesses. Please note that not all assets require a Conflict of Interest Declaration. Please see the PWGSC Conflict of Interest and Post-Employment Declaration form for an explanation of which assets require a Conflict of Interest Declaration and which do not, at PWGSC.

Liabilities (Passif): refers to holdings for which one is financially obligated according to law. Please note that not all liabilities require a confidential report. Please see the PWGSC Conflict of Interest and Post-Employment Declaration form for an explanation of which kinds of liabilities require a Conflict of Interest Declaration, and which do not.

Outside Activities (Activités extérieures): refers to structured activities outside of PWGSC in which public servants may participate as a part of their personal lives. Examples of outside activities include but are not limited to community boards, outside employment, self–owned businesses and charitable organizations. PWGSC employees must submit a Conflict of Interest Declaration for all outside activities that place them, or could reasonably be perceived as placing them, in a conflict of interest.

Outside Employment (Emploi extérieur): refers to any form of remunerated employment outside of PWGSC, including self–owned and/or partnership-based businesses. PWGSC employees are required to submit a Conflict of Interest Declaration for all outside employment.

Conflict of Interest Declaration: (Déclaration de conflit d'intérêts): refers to a brief disclosure relating to any real, apparent or potential conflict of interest, and all cases of outside employment, affecting PWGSC employees. The report is submitted to the Director General of Labour Relations, Occupational Health and Safety, Compensation, Ethics and Well Being, using the PWGSC Conflict of Interest and Post-Employment Declaration form.

Designated Official (Administrateur désigné): refers to the individual delegated by the Deputy Minister, through the Departmental Instrument of Delegation, with authority to respond to Conflict of Interest Declarations.

Standing Panel (Comité permanent): refers to a committee convened to review Conflict of Interest Declarations.

Committee members include the:

  • Branch/Agency Head (rotating position);
  • Designated Official;
  • Assistant Deputy Minister, Human Resources Branch;
  • Senior General Counsel, Legal Services;
  • Assistant Deputy Minister, Departmental Oversight Branch;
  • Director, Labour Relations; and
  • Manager, Conflict of Interest.

RESPONSIBILITIES AND ACCOUNTABILITIES

The Designated Official is responsible for:

  1. reviewing employee declarations in accordance with the established departmental review process;
  2. advising the employee in writing as expeditiously as possible of the decision as to whether or not a real, potential or apparent conflict of interest exists or may exist;
  3. advising the employee of the necessary measures to take to ensure compliance with the Values and Ethics Code for the Public Sector and the PWGSC Code of Conduct and of the time frame within which such measures are to be taken, in the event that such a conflict of interest does or will exist;
  4. in cases of conflict of interest, following up at the end of the time frame to ensure the employee has complied with the necessary measures; and
  5. sending out semi-annual reminders to all employees.

Employees are responsible for:

  1. taking all possible steps to recognize, prevent, report, and resolve any real, apparent or potential conflicts of interest between their official responsibilities and any of their private affairs;
  2. unless formally approved by the Designated Official, refraining from having private interests that would be unduly affected by government actions in which they participate, or of which they have knowledge or information;
  3. reporting fully and without delay any assets or liabilities that place or may place them in a conflict of interest, using the PWGSC Conflict of Interest and Post–Employment Declaration form submitted to the Director General, Labour Relations, Occupational Health and Safety, Compensation, Ethics and Well-Being, for review;
    1. Additional guidance with regard to assets and liabilities requiring a declaration can be found in the PWGSC Conflict of Interest and Post–Employment Declaration form
  4. in cases of real, apparent or potential conflicts of interest, and all cases of outside/remunerated employment, sending a Conflict of Interest Declaration describing the situation to the Director General, Labour Relations, Occupational Health and Safety, Compensation, Ethics and Well-Being, for review;
  5. reviewing their personal situation at least annually, and as circumstances warrant, and if necessary, submitting a revised Conflict of Interest Declaration to the Director General, Labour Relations, Occupational Health and Safety, Compensation, Ethics and Well-Being, for review;
  6. not knowingly taking advantage of, or benefiting from, information that is obtained in the course of their duties that is not available to the public;
  7. refraining from the direct or indirect use of, or allowing the direct or indirect use of, government property of any kind, including property leased to the government, for anything other than officially approved activities;
  8. not assisting private entities or persons in their dealings with the government where this would result in preferential treatment of the entities or persons;
  9. not interfering in the dealings of private entities or persons with the government in order to inappropriately influence the outcome;
  10. maintaining the impartiality of the public service and not engaging in any outside or political activities that impair or could be seen to impair their ability to perform their duties in an objective or impartial manner;
  11. ensuring that any real, apparent or potential conflict that arises between their private activities and their official responsibilities as a public servant is resolved in the public interest; and
  12. minimizing, when leaving the public service, the possibility of real, apparent, or potential conflicts of interest between their new employment and their former responsibilities within PWGSC.
  13. In addition to the above, employees in the Executive Group, EX minus 1 positions and EX minus 2 positions shall not, without receiving written permission from the designated official, within a period of one year after leaving office:
    1. accept appointment to a board of directors of, or employment with, entities with which they personally, or through their subordinates, had significant official dealings during the period of one year immediately prior to the termination of their service;
    2. make representations for, or on behalf of, persons to any department or organization with which they personally, or through their subordinates, had significant official dealings during the period of one year immediately prior to the termination of their service; or
    3. give advice to their clients using information that is not available to the public concerning the programs or policies of the departments or organizations with which they were employed or with which they had a direct and substantial relationship.

The Standing Panel is responsible for assisting the Designated Official in making decisions reflective of the department's position on conflict of interest.

COMPLIANCE AND REPORTING

  1. Employees who disagree with the measures prescribed by the Designated Official to ensure compliance with the PWGSC Code of Conduct are encouraged to discuss the issue with that Official.
  2. In the event they are unable to resolve the issue, employees may present a grievance against the prescribed measures in accordance with the relevant collective agreements or their terms and conditions of employment.
  3. An employee who fails to comply with the both the Values and Ethics Code for the Public Sector and the PWGSC Code of Conduct may be subject to corrective action up to and including termination of employment.

REFERENCES

Treasury Board of Canada Secretariat Publications

INQUIRIES

Manager, Conflict of Interest and Harassment
Human Resources Branch
Telephone: 819-956-9378