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NRCAN Values and Ethics Code

Table of Content

Message From Our Deputies and Champions

At Natural Resources Canada (NRCan), we are dedicated to improving the lives of Canadians by positioning our nation as a global leader in sustainable resource development. Our work as public servants have a profound and lasting impact on the lives of all the communities we serve. Every day, through our collective efforts, we contribute to fulfilling NRCan’s mandate in ways that reflect the core values of the Canadian federal public sector. It is our privilege and responsibility to carry out this work with integrity, transparency and professionalism.

The NRCan Values and Ethics Code (the Code) is a foundational document that defines the ethical standards expected of all of us in the activities related to our professional duties. It is about who we are and what brings us together as public servants working at NRCan.

In renewing the Code, we have considered the realities of our department and the importance of ensuring that it remains a relevant and practical guide for all employees. This updated version incorporates the input of various communities of practice, bargaining agents, stakeholders, and senior leadership across NRCan, reflecting the diverse perspectives and expertise within our organization. It also emphasizes our commitment to reconciliation, inclusion, and equity, key priorities that are at the heart of NRCan’s mission today and into the future.

 As public servants, we must continuously strive to uphold the Code’s values – respect for democracy, respect for people, integrity, stewardship, excellence, and reconciliation – in our everyday work. These values are not just ideals; they are principles that shape the decisions we make, the way we interact with one another, and the trust we build with the public we serve.  It is also about reinforcing our commitment to fostering a respectful, professional and inclusive workplace. 

The road ahead may present challenges, but as we draw inspiration from the Inuktitut word ajuinnata – which means “never give up, no matter how difficult the task ahead might be” – we are reminded of our shared resilience and commitment to our mission. Together, we will rise to meet whatever challenges come our way, confident in our collective ability to serve Canadians with excellence and integrity. Let this renewed NRCan Values and Ethics Code be a guiding light in our work, helping us to adhere to the highest standards as we continue to serve the people of Canada and to uphold public trust.

Michael Vandergrift (he/him)
Deputy Minister

Jeff Labonté (he/him)
Associate Deputy Minister

Michael Norton (he/him) and Sonia Talwar (she/her)
Values and Ethics Champions

PART 1: Context and Application

1.1 Context

In accordance with section 5 of the Public Servants Disclosure Protection Act (PSDPA), the Treasury Board Secretariat (TBS) established the Values and Ethics Code for the Public Sector (VECPS) in 2011. Section 6 of the PSDPA requires that all departments develop their own codes to complement the broader VECPS. Natural Resources Canada (NRCan) introduced its first Values and Ethics Code in 2012, and now a dozen years later, we provide an updated version to include clarifications, modernized language and new sections, such as the introduction of “reconciliation” as a new value. We have also developed a complementary guidance document titled “Expected Standards of Conduct” which is published as an internal document and referred here as “Annex”. We also took into account the recent (2023) Deputy Ministers’ Task Team on Values and Ethics Report to the Clerk of the Privy Council.

NRCan’s new Code of Values and Ethics (NRCan Code) was developed in consultation with various key stakeholders and bargaining agents and outlines the values and behaviours that are expected of all NRCan employees. It covers ethical risks or potential conflict of interests (COI) situations that the Department or its employees face in their daily work-related activities and supports NRCan’s business culture and operational requirements. The NRCan Code may not address every situation. For example, principles of research ethics are covered in other reference documents, such as the Scientific Integrity Policy. Where clarity is required, employees are expected to consult with their manager or NRCan’s Centre of Expertise in Values and Ethics.

1.2 Application

The VECPS and related directives, policies and guides, including the NRCan Code and the Directive on Conflict of Interest, form part of the Terms and Conditions of Employment of all NRCan employees. The term “employees” refers to indeterminate and term employees, executives, students, casual, seasonal and part-time workers and persons working by means of a secondment. Employees on leave, including leave without pay, continue to be subject to both codes and must continue to abide by them for the duration of their leave. Although they are not public servants, individuals on incoming Interchange Canada assignments, emeritus scientists, volunteers, and contractors are expected to respect, the requirements of the NRCan Code. Order-in-council appointees, such as deputy heads, are subject to the Conflict of Interest Act.

The NRCan Code also includes post-employment Conflict of Interest provisions that apply to persons employed and designated senior officials, or persons in positions identified in the Conflict of Interest (COI) Disclosure Form, for a period of one year after they leave the public service.

While non-compliance with the VECPS and the NRCan Code, including the Expected Standards of Conduct, may result in disciplinary measures, including termination of employment, the primary goal of the NRCan Code is to promote a shared understanding of the roles, responsibilities and expected standards for all employees. This is crucial for both new and longstanding members of the organization to ensure a work environment based on common values and to maintain an ethical culture.

PART 2: Our Values and Ethics

2.1 NRCan Values

In addition to the five core Public Service Values, we are introducing "reconciliation" as a vital aspect of our work. This NRCan value emphasizes our commitment to building respectful and meaningful relationships with Indigenous communities. It serves as a guiding principle in our initiatives and decisions, ensuring that we actively support reconciliation in all aspects of our operations. By prioritizing this value, we aim to contribute to a more inclusive and equitable future for all.

NRCan employees are expected to demonstrate these values in their daily decisions, actions, processes, and systems. Similarly, employees can expect NRCan policies and procedures to respect these values and can expect to be treated in accordance with these values by their managers and colleagues.

I. RESPECT FOR DEMOCRACY

The system of Canadian parliamentary democracy and its institutions are fundamental to serving the public interest. Public servants recognize that elected officials are accountable to Parliament, and ultimately to the Canadian people, and that a non-partisan public sector is essential to our democratic system. At NRCan, we recognize that loyalty plays a pivotal role as well, as we dutifully carry out the lawful decisions of leaders, supporting ministers in being accountable to both Parliament and the Canadian people. Additionally, our responsibility to decision-makers is exemplified by our dedication to providing comprehensive information, analysis, and advice, always striving to be transparent, candid, and unbiased. Aligning our efforts, energy, and expertise with government and departmental priorities, NRCan employees are dedicated to serving the public with impartiality.

Furthermore, NRCan recognizes the importance of Indigenous rights and perspectives, including respecting the type of governance of all Indigenous communities, their rights to self-determination, and the commitment to adhere to the United Nations Declaration for the Rights of Indigenous Peoples Act.

II. RESPECT FOR PEOPLE

Respect for people is a fundamental NRCan value. Treating all people with respect, dignity and fairness is fundamental to our relationship with the Canadian public and contributes to a safe and healthy work environment that promotes engagement, openness and transparency. The diversity of our people and the ideas they generate are the source of our innovation.

By embodying this value, we uphold a set of principles aimed at fostering a harmonious, inclusive, safe and accessible work environment. At NRCan, we demonstrate this by treating every person with respect and fairness, valuing the diverse perspectives and strengths of our multicultural workforce, and actively contributing to the creation and maintenance of safe and healthy workplaces, both physically and psychologically, free from any form of harassment, discrimination and violence.

In our interactions, we work together in a spirit of openness, honesty, and transparency, fostering engagement, collaboration, and respectful communication. When faced with interpersonal or professional conflicts, we strive to reach a resolution in a fair, timely and informal manner, when possible.

Furthermore, we demonstrate sensitivity towards the unique values, socio-cultural traditions, history, and needs of Indigenous peoples, facilitating the path towards reconciliation. This entails active learning, unlearning, and listening to Indigenous voices, while allowing space for their inclusion and adjusting systems to accommodate Indigenous ways of knowing and doing. It also involves acknowledging the voices of Indigenous federal employees, addressing challenges, and implementing changes with accountability and transparency, as highlighted in Many Voices One Mind: A Pathway to Reconciliation.

We prioritize understanding and accommodation for individuals with both visible and invisible disabilities, fostering a workplace that promotes mental and physical well-being. By acknowledging and embracing diverse perspectives and practices, as well as cultivating Indigenous cultural competency, we ensure respectful and harmonious interactions with individuals from all backgrounds. We actively oppose harassment, discrimination, and violence in the workplace, refraining from any language, gestures, or actions that could belittle, embarrass, or intimidate others. Upholding principles of honesty, commitment, and respect in our relationships is paramount.

NRCan employees demonstrate pride and respect for their department. We embody behaviors, professionalism, and language that reflect NRCan’s corporate image and reputation. We recognize the importance of maintaining a balance between work and personal lives, and always respecting and upholding the inherent human dignity of every person we encounter.

III. INTEGRITY

Integrity is a paramount NRCan value that underpins the actions of employees, guiding our commitment to serving the public interest. By adhering to the highest ethical standards, we uphold integrity by conducting ourselves in a manner that conserves and enhances public confidence in the honesty, fairness and impartiality of the public sector. It transcends mere adherence to the law; it entails that we never leverage or use our official position for personal gain or to favour or disadvantage others. We conduct our research, science and daily work responsibility in a manner that ensures integrity and honesty in our pursuit of knowledge.

As NRCan employees, we must be vigilant in identifying and resolving any potential conflicts of interest, ensuring our private affairs never compromise the public interest. By acting in a way that fosters trust from our employer, we solidify our responsibility as custodians of the public trust.

Moreover, we understand that the means to achieve results are as important as the outcomes themselves. Thus, NRCan creates a safe space and supports employees in proactively raising ethical concerns to management and/or the Centre of Expertise in Values and Ethics, as well as reporting inappropriate conduct to the Senior Internal Disclosure Officer, to establish and maintain a culture of trust and accountability.  We also cultivate an environment that supports and promotes scientific integrity, as outlined in the Scientific Integrity Policy. Ultimately, we remain dedicated to our obligations and honour our commitments within the workplace and towards stakeholders, reinforcing the foundation of integrity upon which their service is built.

IV. STEWARDSHIP

At NRCan, the value of Stewardship guides our conduct by emphasizing the responsible and efficient utilization of public resources, for both the short and long term. NRCan employees are entrusted with managing public money including research funds, property, resources conducting research, and we hold the responsibility to use them effectively and efficiently.

We must consider both present and long-term consequences of our actions on people and the environment. We care about sustainability and recognize our key role in the stewardship of natural resources, the natural environment and the well-being of people.

Knowledge and information are valuable assets that should be acquired, preserved, and shared appropriately.

Transparency is crucial, and all transactions, including purchasing, contracting, and travel, must always withstand scrutiny.

Privacy and discretion play significant roles in stewardship. As NRCan employees, we are obligated to handle sensitive information with utmost respect for individuals' privacy. Information is used only for its intended purpose and not shared with unauthorized parties, either within or outside the department.

Furthermore, the use of government assets is restricted to official purposes or as explicitly authorized. This ensures that resources are dedicated solely to serving the public interest and maintaining the highest standards of integrity and accountability in all actions and decisions made by public servants. By upholding the principles of stewardship, we demonstrate our commitment to responsible governance and contribute to building a trustworthy and effective public administration that benefits society.

V. EXCELLENCE

Excellence is a core value upheld by NRCan employees. It guides our actions and behaviours as we serve the nation. We demonstrate professional excellence by advancing science and innovation, and by providing fair, timely, efficient, and effective services and programs that not only meet the needs of the public but also respect Canada's official languages, reflecting the nation's diversity and inclusivity. Engagement, collaboration, effective teamwork and professional development are essential to achieving excellence.

Striving for continuous improvement, we are dedicated to enhancing the quality of policies, programs, and services we provide, ensuring they remain responsive and relevant in a rapidly changing world. By fostering a work environment that encourages teamwork, learning, and innovation, we create a culture of growth and progress, allowing for the generation of innovative ideas and efficient solutions to complex challenges. Moreover, we are dedicated to fostering an inclusive, diverse and equitable workforce that offers fair opportunities, at all levels, including but not limited to Indigenous peoples, individuals with disabilities, racialized groups, and members of the 2SLGBTQI+ community. As NRCan employees, we are committed to working closely with Indigenous partners, recognizing the importance of developing effective strategies and service approaches that positively affect Indigenous peoples’ development and living conditions.

Taking full responsibility for our actions, we embrace a culture of learning, seeking valuable insights from our experiences to continuously improve our performance and delivery of science, programs and services. With an unwavering dedication to reaching our fullest potential, we collaborate and consult with internal and external stakeholders, promoting an inclusive and participatory decision-making process. We cultivate creativity, adaptability, and innovation by embedding inclusion, diversity, equity, and accessibility into our core. We aim to model and promote inclusive practices in transforming the natural resource sectors, ensuring accountability to all communities now and in the future.

Finally, our actions demonstrate a commitment to workplace safety and security, both physically and psychologically, enabling us to fulfill our duties diligently and efficiently. Through the value of excellence, NRCan employees strive to create a stronger, more dynamic, and inclusive nation for all its citizens.

VI. RECONCILIATION

Reconciliation is an essential fundamental NRCan value that holds immense significance within the public service, particularly in the context of Indigenous relations. As a federal department, our commitment to reconciliation begins with a deep understanding and acknowledgment of the historical and current colonial practices that have shaped the relationship with First Nations, Inuit, and Métis peoples and communities.

Reconciliation necessitates a critical review of our existing processes and a willingness to make fundamental changes, where necessary. This step ensures that our actions align with Indigenous ways of understanding and working but also with the stewardship of the land and its diverse ecosystems, promoting consistency and harmony between our goals, the well-being of all species and the aspirations of Indigenous communities. Moreover, as NRCan employees, we recognize the importance of the preservation and revitalization of Indigenous languages, cultures, and traditions within our organization and the broader society. By actively supporting initiatives that promote cultural diversity and empower Indigenous communities, we can contribute to the healing and strengthening of our nation's social framework.

An integral aspect of reconciliation involves incorporating Indigenous perspectives into all facets of our work at NRCan. This necessitates a concerted effort to increase Indigenous representation at all levels of the organization, including leadership roles. We must actively reform our methods of engagement with Indigenous communities to ensure their voices are not only heard but meaningfully considered and integrated into our decision-making processes. Additionally, fostering educational opportunities and economic empowerment for Indigenous peoples contributes to creating a sustainable development and equitable access to resources, paving the way for long-term prosperity and well-being.

In essence, reconciliation demands a holistic and sustained commitment from all sectors of society, including government institutions like NRCan. By embracing Indigenous perspectives, honouring treaty rights, and upholding the principles of equity and justice, we can forge a future built on respect, understanding, and shared prosperity. NRCan employees are encouraged to read the Pathways to Reconciliation: NRCan’s framework for reconciliation in order to further their understanding and gain comprehensive insight on Reconciliation.

2.2 NRCan Ethics and Expected Standards of Conduct

At NRCan, we are committed to upholding and promoting high standards of conduct, in accordance with both the VECPS and the NRCan Code. Expected Standards of Conducts may be found in Annex B (accessible exclusively to NRCan employees). These standards provide general guidelines on various ethical issues, clarify conduct expectations and offer guidance on NRCan employees’ everyday work.

Annex B must be read and applied in conjunction with the NRCan Code, as it describes expectations related to our professional responsibilities, our duty of loyalty and our obligations of fairness, respect and dignity. Additionally, it addresses the use of social media and networks, the care and use of government property and electronic networks, intellectual property and the use of generative artificial intelligence. Expected Standards of Conduct (Annex B) also covers the topics of confidentiality and disclosure of information, as well as impairment.

PART 3: Conflict of Interest and Post-Employment

The following section outlines the various types of conflicts of interest, as well as the roles and responsibilities of NRCan employees in preventing and resolving these conflicts, both during their employment with NRCan and after they leave the organization.

3.1 Conflict of Interest

As NRCan employees, we must maintain public confidence in the impartiality and objectivity of NRCan and the public service by preventing and avoiding situations that could give the appearance of a conflict of interest, result in a potential for a conflict of interest or result in an actual conflict of interest. When this document refers to “conflict of interest” (COI), it refers to all three types, real, apparent and potential conflict of interest.

In the public sector, the appearance or perception of conflict of interest can be as damaging as an actual conflict of interest. The target audience is not the expert who fully understands all aspects of a given situation, but rather the average citizen or a competing business who could reasonably believe there is a conflict of interest. More information on Apparent Conflict of Interest is available on the Government of Canada website.

It is impossible to foresee every situation that could give rise to a conflict of interest. When in doubt, NRCan employees should consult the Centre of Expertise in Values and Ethics.

3.2 Requirement to Report

NRCan employees are required to report within 60 days of their employment, or when there is a change of position or a substantial change in responsibilities, about their personal assets, liabilities or outside activities (teaching, outside employment, personal business, other personal engagements, etc.). Additionally, certain work-related activities may also pose risks to employees or the organization and should be reported to the Centre of Expertise in Values and Ethics. To comply with these expectations, employees are required to submit a detailed Conflict of Interest (COI) Disclosure Form to the Conflict of Interest Administrator.

The COI Disclosure Form, and related assessment, document the employee’s due diligence and help to protect both the employee and the Department by preventing and managing conflict of interest situations. When required, the Centre of Expertise in Values and Ethics assists employees (and their managers) in identifying and implementing mitigation measures.

Our strongest tools in addressing and mitigating ethical issues and conflicts of interests are awareness, frank and respectful discussion, and the adoption of a wide point of view to consider the breadth of influence our actions and decisions may have.

3.3 Confidentiality

Compliance with NRCan's Code of Values ​​and Ethics is a condition of employment. Information collected through the COI Disclosure Form provides an avenue for NRCan to better assess potential ethical risks and provide guidance to employees on the measures that must be taken to prevent these risks. The provided information is confidential and may be shared on a need-to-know basis. Appropriate measures are taken to secure personal information collected through the COI Disclosure Form, that can only be used or disclosed for the purposes for which it was collected, as per the requirements of the Access to Information Act, the Privacy Act, and NRCan’s Departmental Security Policy.

3.4 Prevention of Conflict of Interest

NRCan employees maintain public confidence in the objectivity of the public service by preventing and avoiding situations that could give rise to the appearance of a conflict of interest, result in a potential for a conflict of interest or result in an actual conflict of interest.

Our strongest tools in addressing and mitigating ethical issues and conflicts of interest are awareness, frank and respectful discussions, and the adoption of a wide point of view to consider the breadth of influence our actions and decisions may have. We recognize that ethical dilemmas and conflicts of interest (real, apparent or potential) are a part of every employee’s life. Ultimately, each one of us is responsible for preventing, avoiding and mitigating conflict of interest situations.

3.5 Conflict of Interest During Employment

As outlined in section 3.2 Requirement to Report, regardless of the nature of the conflict of interest (e.g., real, apparent or potential), NRCan employees are required to report in writing, using the COI Disclosure Form any outside activities, assets or interests in relation to their personal affairs or official duties that could give rise to a real, apparent or potential conflict of interest.

3.5.1 Gifts, Honoraria, Hospitality, Travel and Other Benefits

3.5.1.1 Acceptance

We are expected to use their best judgment to avoid situations of real, apparent or potential conflict of interest by considering the following criteria on gifts, hospitality and other benefits and in keeping with this Code, the Values and Ethics Code for the Public Sector and the Treasury Board Directive on Conflict of Interest.

Acceptance of gifts, hospitality, travel, and other benefits for work-related activities is permissible only if these benefits meet all the following criteria:

  • they are infrequent and of minimal value such as low-cost promotional objects, simple meals, or souvenirs with no cash value (we use reasonable judgment to determine “minimal value” as it does not correspond to a specific dollar amount);
  • they are within the normal standards of courtesy, hospitality, or protocol;
  • they arise out of activities or events related to official duties; and
  • they do not compromise or appear to compromise our integrity or that of NRCan in any way.

Whenever possible, we decline any gifts, hospitality or other benefits that may have a real, apparent or potential influence on our objectivity in carrying out our official duties and responsibilities, or that may place us under obligation to the donor. In case of doubt, we recognize that the best practice is to decline the gift, hospitality, or other benefits and act accordingly.

3.5.1.2 Situations Where it May be Impossible to Decline a Gift, Hospitality, Other Benefits

In instances where NRCan employees are faced with situations where it is impossible to decline gifts, hospitality or other benefits that do not meet the above criteria, or where it is believed that there is sufficient benefit to NRCan to warrant the acceptance of certain types of hospitality, the employee and manager are expected to seek written direction from the Conflict of Interest Administrator. The Conflict of Interest Administrator will provide a written assessment indicating whether the offer should be declined or accepted, and if accepted, whether it should be retained by NRCan, donated to charity, disposed of, or retained by the NRCan employee in addition to any applicable risk mitigation measures.

3.5.1.3 Honoraria for participation into conferences and other events

As NRCan employees, if we participate in events (speaker at a conference, panel, etc.) in our official capacity, we must not accept any form of honorarium or additional monetary compensation, regardless of whether such participation was during or outside work hours.

3.5.1.4 Travel Offers from a Third Party

On occasion at NRCan, third parties offer to pay for an employee’s travel expenses to events such as, but not limited to, conferences (speaker or guest), seminars, etc. Ideally, management agrees that the benefit to NRCan justifies such participation, and a source of departmental funding can be identified to cover the related costs. Alternatively, a completed Assessment Tool - Offer of Third Party Funded Travel that addresses the issues of conflict of interest and conflict of duty should be submitted to the director for review and approval, and to document due diligence. Then a copy must be provided to the Conflict of Interest Administrator for their review and recommendations.

We recognize that this does not preclude us from obtaining proper financial and other appropriate approvals, and the requirements of policies such as the Policy on Third Party Funding of Departmental Travel must be met. Direct payment of funds by a third party to a departmental employee, including honoraria and additional monetary compensation, is not permitted.

3.5.2 Personal Assets

We are required to evaluate our assets or interests in companies with whom NRCan has entered or may enter into contractual obligations or in industries related to the mandate or activities of the Department. We must take into consideration the nature of our official duties and the characteristics of our assets or interests (e.g., self-directed investments, patents or other intellectual property, etc.), and must report all assets listed in the COI Disclosure Form. In some cases, we may be required to divest those assets. We may not sell or transfer assets to family members or anyone else for the purpose of circumventing the compliance requirements.

The Conflict of Interest Administrator and the Centre of Expertise in Values and Ethics will consult TBS, Finance or any other experts as required when assessing assets to ensure adherence to the VECPS and the NRCan Code.

3.5.3 Professional and Personal Engagements

3.5.3.1 Speaking at Conferences

On occasion, NRCan employees may be asked by third parties to teach, speak at or be a guest at conferences as a personal activity or part-time employment. Such activities have been identified as high risk to NRCan and its employees with regard to conflict of interest, conflict of duties and duty of loyalty. A COI Disclosure Form must be submitted to the Conflict of Interest Administrator before accepting such offers to ensure a proper assessment under the VECPS and the NRCan Code, thereby protecting both the employee and the Department.

We may accept such invitations as personal activities if all the following conditions are met:

  • The subject is not related to the mandate or activities of the Department.
  • The event is not targeted to a national or international audience.
  • The employee is not presented as speaking for or being an expert of NRCan or of the Government of Canada.
  • The third party is not a potential or current supplier to / collaborator with NRCan.
  • The third party does not lobby or advocate with NRCan.
  • The third party does not receive grants, contributions or other types of funding or payments from NRCan.
  • In the case of teaching or research, it is at neither the college nor university levels.
  • The employee has discussed the event with their manager, who has documented their confirmation that the activity does not conflict with the employee’s duties at NRCan or present other risks to the Department.

Further, before accepting a payment, a reimbursement of costs or an honorarium for such activities, we must assess whether the offer poses a risk of real, apparent or potential conflict of interest or impair in any way our ability to fulfill professional responsibilities and whether the acceptance of the offer would contravene any other legal, financial or policy requirements. Therefore, we must advise our manager to seek their support and obtain all required authorisations.

3.5.3.2 Adjunct Professorships and Research Affiliates

NRCan encourages collaboration with the extramural research and development communities through various activities, including the appointment of NRCan employees to adjunct professorships and research affiliates. These appointments, distinct from indeterminate employment, can be made with Universities, colleges, or other post-secondary educational institutions, both within and outside of Canada. Adjunct professorships and research affiliates also encompass collaborative positions with a National Centre of Excellence or independent research institutes. The role may include contributing to research activities, supervising or co-supervising graduate students, participating on thesis examination committees, and, in some cases, teaching.

For some NRCan employees, such as researchers and scientists, engaging in adjunct professorships or research affiliates can even be part of their work objectives. Nonetheless, due to the external nature of these activities, all adjunct professorships and research affiliates must be reported in writing to the Conflict of Interest Administrator, once management’s support is confirmed. This ensures that relevant guidance on potential conflicts of interest is provided prior to receiving final approvals from management. When these activities are mandated by management, management will be responsible to contact the Conflict of Interest Administrator. Additionally, any potential activities that extend beyond the initially agreed-upon scope must also be reported.

3.5.3.3 Outside Employment / Personal Business

NRCan employees are allowed to engage in employment outside the public service or may start or own a  personal business unless the employment or personal business activities are likely to give rise to a real, apparent, or potential conflict of interest that would undermine the impartiality of the public service or the objectivity of NRCan, or would interfere with their capacity to perform their employment related duties  Employees are expected to report outside employment or their personal business using the COI Disclosure Form.

We are required to report to the Conflict of Interest Administrator if we become a consultant and/or do business with the Government of Canada and receive a benefit or income either directly or indirectly from a contractual agreement with the Government of Canada. The Conflict of Interest Administrator will determine whether the arrangement presents a real, apparent or potential conflict of interest, and may recommend that the contract be modified or terminated.

3.5.4 Political Activities

NRCan employees have the right to engage in political activities if it does not impair and is not perceived to impair their ability to perform their duties in a politically impartial manner.

When we are considering involvement in political activities we seek the advice of our manager and of NRCan’s Designated Political Activities Representative (DPAR) before taking any action. The DPAR will assess the file and liaise with the Public Service Commission (PSC) as required to ensure the processing of the request for the PSC’s approval. Such PSC approval is required before we undertake any activity relating to a political activity and/or seek the nomination for or are a candidate in a federal, provincial, territorial or municipal election.

Similarly, if we are subject to this policy but not subject to Part 7 of the Public Service Employment Act (e.g., casual and part-time workers) and wish to engage in any political activity, we are required to report the proposed activity to the Conflict of Interest Administrator.

3.5.5 Solicitation and Fundraising

With the exception of fundraising for officially supported activities such as the Government of Canada Workplace Charitable Campaign (GCWCC), Canadian Legion Poppy Fund, and Canadian Blood Services / Héma-Québec, we may not solicit gifts, hospitality, other benefits or transfers of economic value from a person, group or organization in the private sector who has dealings with the government. When fundraising for such official activities, we must ensure that we have prior written authorization from the Conflict of Interest Administrator to solicit donations, prizes or contributions in kind from external organizations or individuals.

Furthermore, we must not solicit donations on NRCan property or use NRCan resources for such purposes, including approaching colleagues or organizations that do business with NRCan. This prohibition includes posting announcements or sending emails for donations. Conducting lotteries or games of chance is also prohibited unless the appropriate license is obtained, including 50/50 raffles where proceeds are shared with charities.

However, requesting contributions for gifts (e.g., for new parents or in memory of a deceased colleague) is not considered solicitation, provided participation is optional and no one feels pressured to contribute.

The Conflict of Interest Administrator may require that the activities be modified or terminated where it is determined that there is a real, potential or apparent conflict of interest or an obligation to the donor.

3.5.6 Contracts and Contracting

Concepts of fairness, openness, and transparency in the Government of Canada procurement activities are exhibited through compliance with the Financial Administration Act, the Government Contracts Regulations, as well as international and national trade agreements, where appropriate. The Government of Canada's procurement activities are also governed by comprehensive land claims agreements with Indigenous peoples.

Public servants serve the Canadian public by procuring goods and services to achieve the objectives approved by the Government of Canada. In performing these activities, including defining requirements and evaluating bids/offers/arrangements, NRCan employees abide by the laws, regulations, and policy instruments (for example, TBS policy instruments, and more) established by the government.

When negotiating and/or awarding contracts, we must not:

  • grant preferential treatment or assistance, or advantages to family, friends, or other person or entity, and
  • disadvantage entities or persons dealing with the Government of Canada (for example, due to personal antagonisms or bias)

3.5.7 Administration of Grants and Contributions

A large portion of NRCan’s annual budget goes toward funding programs and program delivery creates frequent points of interaction between Canadians and public servants.

It is key that NRCan employees maintain objectivity in all interactions with the public and particularly during the Grants and Contributions application intake process as well as when assessing applications for funding. It can be a challenge to keep a proper balance between two key functions: (1) supporting the best interests of the community while (2) respecting the Government of Canada’s obligation to remain accountable to Canadians for the best use of public funds.

When working with potential supporters, we recognize that several potential situations exist, which program delivery staff and management should be aware of and avoid to the greatest extent possible:

  • telling an organization exactly what it should or should not do;
  • completing the application for the recipient;
  • taking sides with one section of a group or community against another; or
  • reviewing or assessing an application for funding if they have an existing relationship with potential proponents, or proponent organizations in any capacity. This applies to all members of review committees and managers who may sit on a proponent organization’s board.

A tool has been developed by the Centre of Expertise for Grants and Contributions to ensure any perception of conflict of interest is considered and handled appropriately in the department. The Grants and Contribution Conflict of Interest Attestation Form must be completed for each funding project file and comprises part of each agreement file.

3.5.8 Avoidance of Preferential Treatment

NRCan employees are not to use their position or official identification, title, or authority to obtain personal benefit; to exert influence; to obtain or appear to obtain any privilege, favour for themselves or others.

We are also not to promote or grant access to NRCan premises to third parties for the purpose of promoting, providing, or selling goods or services not related to official duties, with the exception of approved activities (e.g., the GCWCC).

3.5.8.1 Family, Relatives and Friends

Any NRCan employee who is in a position to influence or makes decisions regarding situations that may reasonably be expected to involve their family, friends or other personal contacts is in a real, apparent or potential conflict of interest. This includes areas of activity such as staffing, contracting and procurement, managing contribution agreements and grants, and employee recruitment. Such situations are to be reported to the manager as soon as it becomes known to the employee. The nature of closeness and visibility of the relationship are factors in determining mitigation measures that will be applied. At minimum, the employee should be distanced from the activity in question. This separation also applies to performance assessments and leave approvals, financial approvals and any other approval required for employee activities, and it should be maintained during acting situations.

Furthermore, close personal relationships that may not satisfy the legal definition of family contained in Annex A, “Definitions,” but could still create the appearance of preferential treatment, must be avoided in all work-related activities. As NRCan employees, we are responsible for identifying any potential conflicts of interest, reporting them, and taking appropriate steps to avoid them.

3.5.8.2 Relationship/Partnership with External Stakeholders

As NRCan employees, we are called upon to have contact with a variety of stakeholders. It is important to be, and be perceived as being, impartial and objective in all our dealings with our stakeholders, and to remember that we represent NRCan and the Government of Canada. Care must be taken to keep our relationships with external stakeholders at an arm’s length and to avoid any real, apparent or potential conflict of interest.

In small communities, NRCan is often a visible and significant part of the community. In such cases, it may be a greater challenge for us to keep our professional and personal lives separate. Maintaining our professional demeanour in public and assessing the effect of our personal behaviour on our professional roles becomes especially important in these circumstances.

3.5.8.3 Reporting Relationships

Given that managers and supervisors are expected to be unbiased and fair in managing their teams, a reporting relationship between family members or friends is a real conflict of interest and should be avoided since it creates the appearance of, and may result in, preferential treatment. The nature and visibility of the relationship are factors to consider in determining the extent to which the definition of family may be applied. In cases where it is impossible to avoid the conflict of interest, management should assign certain responsibilities regarding the reporting employee (performance assessment, leave approval, financial approvals, etc.) to another supervisor, or take other administrative measures to minimize the risk of a conflict of interest. These cases must be reported to the Conflict of Interest Administrator.

3.5.9 Serving on Board of Directors

NRCan employees’ participation on a board of directors can foster good relations with stakeholders and the public, whether membership arises from the employee's private interests or from official duties. However, the risks of conflict of interest or conflict of duties as well as any potential liability issues that can arise from this outside activity must be addressed. As such, participation on boards of directors is deemed to be a reportable activity and must be disclosed as soon as possible, ideally prior to assuming the role.

3.5.10 Sharing and Showcasing NRCan’s Research

As NRCan is a science-based department, sharing and showcasing research is critical and highly beneficial to the delivery of its mandate. While engaging with the broader scientific community and/or general public, we must respect existing legal constraints on information disclosure and exercise caution and prudence in the communication of classified or sensitive scientific or research information. For more on communication and dissemination of research and scientific findings, please consult the Scientific Integrity Policy.

3.6 Preventing Conflict of Interest Prior to and After Leaving NRCan

All NRCan employees must, before leaving their position and for one year after their departure, minimize the risk of real, apparent, or potential conflicts of interest between their responsibilities at NRCan and any external employment or activities.

3.6.1 Prior to Leaving NRCan

Before leaving our employment with NRCan, we must disclose our intentions regarding any future outside employment or activities that may pose a risk of conflict of interest with our current responsibilities and discuss potential conflicts with our manager and the Conflict of Interest Administrator if necessary.

We are to return all government property and valuables issued to us by NRCan when we leave our position, are transferred, or reassigned or are asked to do so by the proper authority. This includes but is not limited to all NRCan records, paper documents, any form of portable storage with electronic information (USB drive, CDs, external hard drive, etc.), work phone, credit and travel cards, unless authorized by their manager to retain them.

3.6.2 Post-Employment Restrictions for Designated Positions

NRCan employees in designated positions (EX, EX-1, EX-2, and their equivalents) are subject to certain restrictions for one year after leaving NRCan and the public service. Other employees, due to the nature of their roles as identified in the COI Disclosure Form, are also subject to the same post-employment obligations. Employees in designated risk groups are informed of their post-employment obligations upon hiring and again after completing the COI Disclosure Form.

Before leaving office and during this one-year limitation period, employees in these designated positions are required to report to the Conflict of Interest Administrator all firm offers of employment or proposed activity outside the public service that relate to the mandate or activities of NRCan or to their responsibilities while at NRCan. They are also to disclose immediately the acceptance of any such offer. In addition, these employees may not, during this one-year period, do any of the following without the Conflict of Interest Administrator’s authorization:

  • accept an appointment to a board of directors of, or employment with, third parties with which they had significant official dealings during the period of one year immediately prior to the termination of their service. The official dealings in question may either be directly on the part of the public servants or through their subordinates;
  • make representations to any government organization on behalf of parties outside of the public service with which they had significant official dealings, during the period of one year immediately prior to the termination of their service. The official dealings in question may either be directly on the part of the public servant or through their subordinates; or
  • give advice to their clients or employer using information that is not publicly available concerning the programs or policies of the departments or organizations with which they had a direct and substantial relationship.

Fostering collaboration with suppliers or stakeholders as a stepping-stone to seek outside opportunities for personal gain, such as employment, contracts or post-retirement benefits for self, family, or friends, will not be tolerated.

Assistant Deputy Ministers and their equivalents are also subject to the Lobbying Act. In the case of any conflict between this code and the Act, the Act takes precedence.

3.6.3 Waiver or Reduction of Limitation Period

NRCan employees are to apply to the Conflict of Interest Administrator when seeking for a written waiver or reduction of the post-employment limitation period. The employee must provide sufficient information to assist in deciding as to whether to grant the waiver, taking into consideration the following criteria:

  • the circumstances under which the termination of their service occurred;
  • the general employment prospects of the employee or former employee;
  • the significance to the government of information possessed by the employee or former employee by virtue of that individual’s position in the public service;
  • the desirability of a rapid transfer of the employee’s or former employee’s knowledge and skills from the government to other governmental, private or non-governmental sectors;
  • the degree to which the new employer might gain unfair commercial or private advantage by hiring the employee or former employee;
  • the authority and influence possessed by that individual while in the public service; and
  • any other consideration at the discretion of the Deputy Minister.

The Conflict of Interest Administrator will assess the file and make a recommendation for the Deputy Minister’s authorization as appropriate.

PART 4: Resolution of Values and Ethics Issues

NRCan Employees are encouraged to discuss and report values and ethics issues in a timely manner, so that early and appropriate steps can be taken to prevent and resolve these issues. Various avenues of resolution are available, depending on the nature of the issue and the individual(s) involved.

As a first step, we are encouraged to discuss and seek advice from our supervisors or managers on the measures that should be taken to prevent and resolve these matters. Managers and employees can also seek advice and guidance from the Centre of Expertise in Values and Ethics.

When faced with an ethical dilemma, the following decision-making steps can assist us in determining an appropriate course of action. We should ask ourselves the following questions:

  • What is difficult about this situation?
  • Is what I want to do legal and consistent with guidelines, policies and this Code?
  • Is what I want to do consistent with our departmental values?
  • What are the consequences and impacts of the possible actions and decisions? Do they in any way impact my ability, real or perceived, to do my job effectively and impartially?
  • Have I asked for advice from an independent, trusted person or service?
  • How would the media, my management or the general public perceive the situation if my actions were reported on the front page of a newspaper?
  • Am I comfortable with the decision I am about to make?

In case of doubt, we are expected to discuss these questions directly with our immediate supervisor or manager, or seek guidance from the Centre of Expertise in Values and Ethics.

Disclosure of Wrongdoing

As provided by sections 12 and 13 of the Public Servants Disclosure Protection Act (PSDPA), when we have information that could indicate a serious breach of this Code, we should bring this matter to our immediate supervisor, the Departmental Senior Officer for Disclosure, or the Public Sector Integrity Commissioner Public Sector Integrity Commissioner. The PSDPA prevents anyone from taking any reprisal against a public servant, because the public servant has made a protected disclosure or has, in good faith, cooperated in an investigation into a disclosure.

Although this Code sets standards of behaviour for all employees of NRCan, they are not all-inclusive. The absence of a specific standard of behaviour does not mean that an action is condoned and consequently it may still be subject to disciplinary measures up to and including termination of employment. Every NRCan employee is responsible for their choices and actions.

PART 5: Contacts/Resources

NRCan is committed to supporting their employees and managers in the compliance with the Code. Below is a list of contacts and resources to help navigate and continue the dialogue on the Code.

Values and Ethics

Employees are encouraged to discuss any questions they may have on the Code with their manager or supervisor first. Where additional guidance is needed, employees and managers are encouraged to contact the Centre of Expertise in Values and Ethics.

Disclosure of Wrongdoing

The senior officer for disclosure of wrongdoing helps promote a positive environment for disclosing wrongdoing and deals with disclosures of wrongdoing made by public servants of their organization. The senior officer for disclosure is responsible for supporting the Deputy Minister in meeting the requirements of the PSDPA. For information or to make a disclosure please consult the Disclosure of wrongdoing intranet webpage, or contact the Senior officer for Disclosures’ email.  Alternatively, the Public Service Integrity Commissioner can be reached by phone: 613-941-6400 or 1-866-941-6400 or through an online submission.

Employee Assistance Program

The Employee Assistance Program (EAP) offers confidential support services to employees and managers who are experiencing a challenging personal situation (e.g., conflicts at work, health issues, substance misuse, abusive relationships, etc.) that may affect their health, personal or professional lives. To learn more on the EAP, employees and managers are encouraged to consult the Wellness Program or contact the EAP directly at 1-800-268-7708.

Harassment and Violence Prevention and Resolution

NRCan is committed to a harassment and violence free workplace and to respect the right of all individuals working at NRCan. To learn more on the mechanisms available to employees to prevent and resolve situations of harassment and violence in the workplace, employees and managers are invited to contact the Harassment and Violence Prevention Program.

Informal Conflict Resolution Services

Conflict management provides employees and managers with a confidential, neutral forum in which to discuss and resolve workplace conflicts before initiating a formal process, or after putting a formal process on hold to attempt to resolve the conflict informally. Employees and managers are invited to call 1-844-899-3609 or email to obtain further information or services.

Other Resources

Managers can also consult their labour relations advisor and employees may contact their union representative for additional support.

PART 6: References

The following is a list of references that relate to the Values and Ethics Code for the Department of Natural Resources Canada. It is by no means exhaustive, but it includes the most relevant material.

Acts and Laws

Treasury Board Secretariat Policies and Directives

NRCan Policies, Guidelines and tools

  • Learn more about Ethics - The Source
  • NRCan’s Conflict of Interest Disclosure Form
  • NRCan’s Guidelines for Scientific Publications
  • NRCan’s Scientific and Technical Publications Policy
  • NRCan’s Department Security Policy
  • Policy on Management of Intellectual Property Assets
  • Scientific Integrity Policy
  • SIP Breach Process/Guidelines

Mandatory Training

Other

ANNEX A: Definitions

Adjunct professorship:
An appointment with a university, college or other post-secondary educational institution, in or outside of Canada, to undertake teaching and/or research activities. Other examples include collaborative positions with a National Centre of Excellence, an independent research institute or post-secondary educational institutes other than universities.
Conflict of duties:
A conflict that arises not because of an NRCan employee’s private interests but as a result of one or more concurrent or competing official responsibilities. For example, these roles could include their primary public service employment and their responsibilities in an outside role that forms part of their official duties, such as an appointment to a board of directors or other outside function.
Conflict of interest (COI):
A situation in which the public servant has private interests that could improperly influence the performance of their official duties and responsibilities or in which this employee uses their office for personal gain.
  • A real conflict of interest exists at the present time;
  • An apparent conflict of interest could be perceived by a reasonable observer to exist, whether or not it is the case; and
  • A potential conflict of interest could reasonably be foreseen to exist in the future.
Conflict of Interest Administrator (COI Administrator):
The Deputy Minister’s delegate for matters relating to conflict of interest, including the following: management of NRCan’s Values and Ethics Program; assessment and ruling regarding employees’ Confidential Reports of assets, liabilities and outside activities; NRCan representative at related interdepartmental meetings and consultations. At NRCan, the Deputy Minister has delegated this responsibility to the Director, Centre of Expertise in Values and Ethics.
Designated Political Activities Representative (DPAR):
The Deputy Minister’s delegate to receive employees’ requests and queries regarding political activities, coordinate and prepare related material for the Deputy Minister’s consideration, and liaise with the Public Service Commission as required for consideration and final approval. At NRCan, the Deputy Minister has delegated this responsibility to the Director, Centre of Expertise in Values and Ethics.
Discrimination
means treating people differently, negatively or adversely because of their race, national or ethnic origin, colour, religion, age, sex (including pregnancy and childbearing), sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, physical or mental disability (including dependence on alcohol or drugs) or pardoned criminal conviction.
Fairness
is one of the guiding values of the Public Service Employment Act. It requires that decisions be made objectively and free from political influence and personal favouritism; policies and practices reflect the just treatment of persons; who also have the right to be assessed in the official language(s) of their choice in an appointment process.
Family
includes common-law partner, child, spouse, family members and persons who are related to an employee by birth, marriage, common-law partnership, adoption, or affinity.
Harassment
is any improper conduct by an individual that is directed at and offensive to another person or persons in the workplace and that the individual knew or ought reasonably to have known would cause offence or harm. It comprises any objectionable act, comment or display that demeans, belittles or causes personal humiliation or embarrassment, and any act of intimidation or threat. It includes harassment within the meaning of the Canadian Human Rights Act and based on protected grounds set out in that Act, namely race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, disability, and pardoned conviction.
Intellectual property
means all rights in any information of a scientific or technical nature, whether oral or recorded in any form or medium and whether or not protectable by patent or copyright, including but not limited to data, techniques, methods, processes, know-how, inventions, designs, formulae, photographs, drawings, plans, specifications, reports, studies, technical and procedural manuals, computer firmware, and computer software, data files, and documentation including, without limitation, patents, copyrights, trade secrets, trademarks, registered industrial designs, any applications for same, and all rights therein.
Non-partisanship
is one of the core values of the Public Service Employment Act. It is essential to a professional public service and responsible democratic government and ensures that appointments and promotions to and within the public service are based on merit and free from political influence. It supports the capacity and willingness of employees to serve governments regardless of political affiliation. It enables employees to provide objective policy advice and administer programs and services for Canadians in a politically impartial manner.
NRCan employee:
A person employed at NRCan, including managers and executives, indeterminate and term employees, individuals on leave without pay, students participating in student employment programs, casual, seasonal and part-time workers and persons working by means of a secondment. Although they are not public servants, individuals on incoming Interchange Canada assignments, volunteers, emeritus scientists and contractors are expected to comply with the requirements of the NRCan Code. Order-in-council appointees, such as deputy heads, are subject to the Conflict of Interest Act.
Political activities:
Defined in Part 7 of the Public Service Employment Act as “carrying on any activity in support of, within or in opposition to a political party; carrying on any activity in support of or in opposition to a candidate before or during an election period; or seeking nomination as or being a candidate in an election before or during the election period.”
Property
includes but is not restricted to vehicles, buildings, space, premises, facilities, uniforms, badges, credentials, files and documents, office equipment and supplies, computers, software, video equipment, and telecommunications devices.
Representativeness
is one of the guiding values of the Public Service Employment Act. It requires that appointment processes be conducted without bias and do not create systemic barriers to helping achieve a public service that reflects the Canadian population it serves.
Senior Internal Disclosure Officer:
Deputy Minister’s delegate responsible for the receipt and proper treatment of disclosures made by public servants under the Public Servants Disclosure Protection Act.
Sponsored travel:
A private organization pays for (i.e., transportation, accommodations, meals, etc.) the public servant to travel and perform official duties in a certain location.
Third party:
Any individual, group or organization external to the Government of Canada, such as a private individual, a business, a society, an association, or a university.
Valuables
include but are not restricted to any items of value, such as government credit cards and telephone calling cards.
Wrongdoing
relates to serious violations that go against the public interest, such as:
  • violating any Act of Parliament or any Act of the legislatures of the provinces or territories;
  • misusing public funds or public assets;
  • gross mismanagement;
  • doing something, or failing to do something, that creates a substantial and specific danger to the health, safety or life of persons or to the environment;
  • seriously breaching the VECPS or NRCan’s Code; and
  • directing or counselling someone to commit a wrongdoing

ANNEX B: Expected Standards of Conduct

Accessible exclusively to NRCan employees.

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