Adam Dodek What lies ahead for public sector

ethics?
Abstract: What principles and dynamics unite public sector accountability offices—
the need for independence, the need for resources, the need for clear mandates and
appropriate powers, and the need for buy-in from those who are being held
accountable? This article explores where the field of public sector ethics is heading
in the future, particularly in light of the tension with partisan politics in a
Parliamentary democracy and the limited legal and administrative tools at the
disposal of accountability/ethics officers. More broadly, this article will examine
the significance of advancing a community of interest and professional standards
across accountability/ethics officers.

Sommaire : Par quels principes et rouages les bureaux de responsabilite du secteur

public sont-ils unis : le besoin d’independance, le besoin de ressources, le besoin de
mandats clairs et de pouvoirs adequats, et le besoin d’acceptation de la part des
personnes qui sont imputables? Cet article etudie l’orientation future du domaine
public en matière d’ethique, surtout en tenant compte des tensions avec les
politiques partisanes au sein d’une democratie parlementaire, et des outils
juridiques et administratifs limites dont disposent les agents responsables a
l’ethique. De manière plus generale, cet article scrute le sens d’ameliorer une
communaute d’inter^ets et des normes professionnelles pour les agents responsables
a l’ethique.

Introduction: facing the challenges of

the 21st century
Public sector accountability offices are still relatively new.1 At the federal
level, the first Ethics Counsellor was only appointed in 1994 and that posi-
tion did not become independent until 2004. The landmark report of John
Tait’s Task Force on Public Sector Values and Ethics was published in 1996.
The Quebec Sponsorship Scandal and the Gomery Commission (2006) pro-
vided the political impetus for developing a new political culture of
accountability, spurred on by the earlier reports of the Auditor General of
Canada (Auditor General of Canada 2002). Academic support was pro-
vided by the influential writings of Professor Donald Savoie (1999, 2003)
among others. The Federal Accountability Act (S.C. 2006, c. 9) was enacted
only in 2006, leading to the creation and strengthening of various account-
ability offices. Similar reforms took place at the provincial and municipal

Adam Dodek is Dean and Professor, Faculty of Law, University of Ottawa.

CANADIAN PUBLIC ADMINISTRATION / ADMINISTRATION PUBLIQUE DU CANADA

VOLUME 61, SUPPL. 1 (MAY/MAI 2018), PP. 102–113
C The Institute of Public Administration of Canada/L’Institut d’administration publique du Canada 2018
V
PUBLIC SECTOR ETHICS 103

levels across the country. These reforms were not coordinated or necessar-
ily coherent. They produced a fragmentary approach to the creation of new
accountability offices, tending to create a multiplicity of offices with narrow
jurisdiction and often modest funding.
Thus, the institutionalization of public sector ethics is still relatively
young. This article explores where the field of public sector ethics is head-
ing in the future. It takes as its point of departure the relative youth and
diversity of approaches to the institutionalization of public sector ethics. It
begins with explaining the failure of political accountability which served
as an important driver in the creation and the strengthening of accountabil-
ity offices. This is not simply history, it continues to provide essential fram-
ing for the operation of public accountability offices in Canada. This article
then considers what should be in the “ethics toolkit” for such offices and
some specific issues of institutional design in constructing accountability/
ethics regimes.

Accountability officers and the failure of

political accountability
Part of the drive for the creation and expansion of accountability
regimes can be attributed to the failure of political accountability in
Canada. Political accountability is the attempt to hold persons who exer-
cise power accountable for the exercise of that power through the politi-
cal process. In Canada’s system of parliamentary democracy, the
doctrine of ministerial responsibility is supposed to hold members of
the executive accountable for their actions to the legislature. It continues
to provide a limited form of accountability in a sense described by a for-
mer Clerk of the Privy Council: “where authority resides, so resides
accountability, and if one has authority to strike a decision, then one has
an obligation to provide an account” (Savoie 2008: 257). The obligation
to provide an account for a decision remains an important part of minis-
terial responsibility.
Another aspect of accountability involves answering for one’s actions
in terms of sanction. In this respect, political accountability has fallen
short of public expectations and helped fuel the drive for external
accountability officers. Similarly, the long-heralded parliamentary sover-
eignty has been constrained since the enactment of the Canadian Charter
of Rights and Freedoms in 1982. However, the Supreme Court recognized
that the Charter does not trump one important aspect of parliamentary
sovereignty: parliamentary privilege (New Brunswick Broadcasting v. Nova
Scotia (Speaker of the House of Assembly), [1993] 1 S.C.R. 319 (SCC); Canada
(House of Commons) v. Vaid, [2005] 1 S.C.R. 667 (SCC)). Parliamentary
privilege protects the right of Parliament and provincial legislatures to
104 ADAM DODEK

regulate and discipline their own members (O’Brien and Bosc 2009;
Maingot 2016).
Yet, these chambers have been hesitant to flex their constitutional
muscles. They have exercised them so rarely that questions arise not
whether such powers continue to exist but whether they exist at all. Par-
liaments have allowed many of their once-cherished powers to atrophy.
This failure of legislature chambers to effectively discipline their mem-
bers has fuelled the growth and demand for accountability offices.
The Senate expense scandal is case in point. It represents an utter failure
of self-regulation by the Senate and a failure of political accountability. It
ultimately led the Senate to turn to outsiders to help restore accountability:
to the Auditor General of Canada and to former Supreme Court justice Ian
Binnie. The case of Senator Mike Duffy was simply the starkest example of
the challenge of accountability faced by the Senate. It exposed the Senate’s
weakness in both articulating ethical standards as well as in enforcing
them.

Parliaments have allowed many of their once-cherished

powers to atrophy. This failure of legislature chambers
to effectively discipline their members has fuelled the
growth and demand for accountability offices

The Senate continues to struggle with accountability. It is unclear that it

will be able to internally address such issues and likely will be required to
surrender autonomy to existing or new public accountability officers in
order to improve accountability and attempt to build some public confi-
dence in the integrity of the work of the Senate and the conduct of individ-
ual Senators. The more recent cases of Senator Don Meredith (Office of the
Senate Ethics Officer 2017; Dodek 2017)1 and Senator Lynn Beyak (Tasker
2017)2 present the most current challenges to the Senate’s ability to deliver
accountability.
The first challenge ahead for public ethics regimes is thus the continuing
failure of political accountability. This puts increased pressure of public
sector accountability officers who instead of being seen as complementing
traditional political accountability are perceived as supplanting it. They
have come under increasing media, public and political scrutiny and may
be involved in open clashes with public officials whose conduct they are
scrutinizing or, more often, criticizing. Such was the case with former
Mayor Rob Ford who directly clashed with Toronto’s Integrity Commis-
sioner. Public sector accountability officers will increasingly become public
figures in their own right and will need to effectively communicate their
mandates and their decisions. As discussed further below, public sector
PUBLIC SECTOR ETHICS 105

accountability officers also must deal with the increasing politicization of

their offices and actions.
These are the some of the challenges that public sector accountability
offices face. We now move to what should be done to improve the effective-
ness of such regimes.

What should be in the ethics toolkit?

Expanding sanctions and other
enforcement mechanisms
Formal sanctions are important enforcement mechanisms because they are
often the most visible forms of enforcement. The impact of “naming” and
“shaming” of ethical offenders has declined within our political culture
and is unclear whether the “Trump factor” will reverberate north of the
border. By the “Trump factor,” I mean breaking all previous political rules
regarding the political impact of the public exposure of lying, questionable
business practices, personal misbehaviour, etc. Further to my previous
comments regarding the decline of political accountability, where informal
sanctions decrease in their effectiveness, greater pressure is placed on the
efficacy of formal sanctions.

The first challenge ahead for public ethics regimes is

thus the continuing failure of political accountability

There is a need to both expand the range of formal sanctions and to

increase their strength. The inclusion of administrative monetary penal-
ties (AMP) in many ethics regimes demonstrates both imperatives. In the
federal Conflict of Interest Act, the maximum AMP is $500 (Conflict of Inter-
est Act, SC 2006, c 2). This amount is simply not high enough to constitute
a serious penalty; it is equivalent to a by-law infraction or a speeding
ticket. Penalties certainly can have symbolic effects, most notably by
attaching an element of shame, embarrassment or humiliation to them. It
is possible that certain penalties could impact a public official’s reputa-
tion and drive them from public office. However, political culture in Can-
ada seems to have moved away from this towards increased tolerance of
contraventions.
I assert that the remarkably low maximum amount of the AMP under
the Conflict of Interest Act undermines the efficacy of an ethics regime pre-
cisely because it makes it look equivalent to a municipal parking system.
Effective ethics regimes need to look to other administrative structures—
health and safety, environmental, etc.—and provide for a range of AMPs
106 ADAM DODEK

which include escalating penalties for repeat offenders and serious pen-
alties for serious contraventions. Sanctions must promote deterrence and
punishment rather than simply being perceived as a slap on the wrist or
a cost of doing political business.

There is a need to both expand the range of formal

sanctions and to increase their strength

Public sector accountability officers need to continue to develop new

enforcement mechanisms as well. For example, the City of Ottawa’s Integ-
rity Commissioner has begun to use compliance agreements to promote
and ensure compliance with the requirements of the government legisla-
tion. Compliance agreements are voluntary agreements wherein the subject
of an investigation agrees to undertake a course of action in compliance
with the act in question with the agreement of the official responsible for
overseeing the act. Such agreements allow public sector accountability offi-
cers to avoid an all or nothing approach; they are not forced to use a ham-
mer to swat a fly. In the words of the Integrity Commissioner of the City of
Ottawa, such agreements allow him to “formally address minor contraven-
tions . . . without having to use sanctions more appropriately reserved for
egregious breaches” (Marleau 2016: 2). Equally important, they give public
sector accountability officers to be able to address minor contraventions
rather than being faced with the all or nothing approach that in many cases
would lead to a decision to forego enforcement and sanctions because of
the perception of overkill. It is necessary to have a range of tools available
to address the range of contraventions of an ethics regime.

Moving beyond complaints and sanctions

The traditional approach of many public sector accountability officers has
been rule-based and complaint-based. They have relied on codes of con-
duct, statutory provisions, complaints, investigations, findings and sanc-
tions. The limits of such an approach have been widely understood over
the past 10–20 years. Such a system is reactive; it does not necessarily
encourage or promote ethical conduct, rather it focusses on allegations of
breach of minimal standards of conduct. In short, this system is essential in
order to deter and punish ethical misconduct but it does not necessarily
promote ethical behaviour.
To this end, public sector accountability officers have promulgated poli-
cies and interpretive guidelines to provide guidance to public officials and
to the public about how relevant provisions will be interpreted. They have
also expanded their duties to include education and information. This is
PUBLIC SECTOR ETHICS 107

likely to continue. And it should because educational efforts are needed in

order to help create an ethical culture.
Many public sector accountability offices include an advisory function
as well. They have been willing to consult with officials for whom they are
responsible about whether a proposed course of conduct would constitute
a violation of a relevant code or statutory provisions. A system that fosters
advance ethical deliberation is positive and should be encouraged. How-
ever, there are also risks involved with such an advisory function.
All too frequently, instead of fostering ethical deliberation, the process
of seeking an advisory opinion has been reduced to ethical minimalism
and a “ruling” by an ethics officer is held up by a political official as a con-
clusive endorsement of a now controversial course of conduct which is
being questioned in the political arena and in the media. In such instances,
the role of public accountability officers is not well-understood by the
public.

Public sector accountability officers need to continue

to develop new enforcement mechanisms

In addition, public officials may purposely politicize the role of public

accountability officers. Public accountability officers are merely comment-
ing on whether a proposed course of conduct would likely violate a partic-
ular rule, not whether such conduct is positive or negative. The decision of
the ethics officer and the integrity of the ethics officer are used for partisan
political purposes by the public official in political trouble with the con-
comitant risk of decreased public confidence in the work of the public sec-
tor accountability official. Consequently, there is a need to revisit this
practice. Refusing to provide such advance rulings would not necessarily
be in the public interest because it would exacerbate the reactive character
of the system instead of being proactive and fostering ethical compliance.
Thus, an effective public sector ethics regime should provide advance
guidance to officials on a proposed course of conduct. However, consider-
ation should be given to expanding and publishing such advice, in certain
circumstances. The response to a confidential inquiry could be amplified to
include caveats that the ethics officer is not condoning or recommending a
particular course of conduct but simply opining on whether it violates the
relevant provisions. In short, the advice would emphasize the minimal
nature of the applicable standard. The advice could also be elaborated
upon to include relevant suggestions for the public official to consider
beyond the minimal standards. Such considerations could also be set out
in policies or guidelines promulgated by the ethics officer. They might
include: the expenditure of public resources, the potential public
108 ADAM DODEK

perception of the course of conduct, the availability of an opportunity to

members of the public as opposed to public officials, perceptions of conflict
of interest, etc.
Regarding publication, there are good reasons for such advice to be con-
fidential. If the advice was not confidential, public officials might not seek
it. However, when public office holders publicly refer to such advice, the
general rules of waiver should apply. Hence, if the public official attempts
to rely on the advice from the ethics officer, the ethics officer should pub-
lish the actual advice. This may provide a disincentive to political officials
from attempting to use such advice for partisan political purposes. It will
also allow the public to have a full account of the advice actually rendered.
It should also contribute to increased ethical reflection about a proposed
course of conduct if the public official (and their advisers) needs to con-
sider the prospect of such advice being published in the future.

All too frequently, instead of fostering ethical delibera-

tion, the process of seeking an advisory opinion has
been reduced to ethical minimalism and a “ruling” by
an ethics officer is held up by a political official as a
conclusive endorsement of a now controversial course
of conduct which is being questioned in the political
arena and in the media

The above measures are still largely reactive; that is, they require either
action by the public official (an inquiry) or against the public official (that
is, a complaint). The role of the public sector accountability officer is largely
reactive. As noted above, the role of such officers has expanded to include
issuing policy guidelines, education and public awareness, however, more
is needed in order to bring such regimes in line with current regulatory
best practices. For example, former Secretary to Cabinet in Ontario and
now Senator Tony Dean has argued that we need to apply regulatory
regime concepts to public sector ethics. He counsels a risk-based approach
to ethics regulation (Institute of Public Administration of Canada 2016).
This would require significant changes to ethics regimes, which are beyond
the scope of this modest article.

Are two (or three, or four) heads better

than one?
How many different ethics officers does a particular jurisdiction need?
There is no easy answer to this question. For example, the City of Toronto
Act, 2006 (S.O 2006, c.11, Sch A) establishes four accountability offices: the
PUBLIC SECTOR ETHICS 109

Auditor General, Integrity Commissioner, Lobbyist Registrar and Ombuds-

man. It is possible that one person could occupy more than one of these
positions, but the City of Toronto Council has chosen to establish four sepa-
rate offices headed up by four separate individuals. In contrast, the City of
Ottawa’s Integrity Commissioner also oversees the Lobbyist Registrar and
is also the Meeting Investigator (http://ottawa.ca/en/city-hall/account-
ability-and-transparency/accountability-framework/integrity-commissio-
ner#role-integrity-commissioner; Lobbyists Registration Act, 1998, S.O. 1998).
The previous paragraph sets out different subject matter jurisdiction for
ethics officers. Resource and efficiency factors will be relevant consider-
ations in determining how many different individuals will be responsible
for these various responsibilities. For smaller jurisdictions, it simply may
not be feasible to have multiple officials. There may not be enough work or
sufficient budget to warrant the creation of multiple offices. But even for
the largest jurisdictions there may be good policy and practical reasons to
fuse various responsibilities into a single office.

If the public official attempts to rely on the advice

from the ethics officer, the ethics officer should publish
the actual advice

Case in point is the jurisdiction over public officials and lobbyists. In

Ontario, the Integrity Commissioner is responsible both for MPPs and lob-
byists.2 However, it is not the case federally where there is a separate Con-
flict of Interest and Ethics Commissioner (http://ciec-ccie.parl.gc.ca/EN/
Pages/default.aspx) and Commissioner of Lobbying (https://lobbyca-
nada.gc.ca/eic/site/012.nsf/eng/h_00000.html). There has been serious
discussion about whether it would be preferable to combine these two offi-
ces into a single office (https://lobbycanada.gc.ca/eic/site/012.nsf/eng/
h_00000.html). The rationale for the proposed reform is because each sepa-
rately regulates different parties to the same transaction. The Commis-
sioner of Lobbying regulates lobbyists’ interactions with public office
holders. The Conflict of Interest and Ethics Commissioner regulates public
office holders’ activities, including those with lobbyists. Both commis-
sioners have inquiry, reporting and penalty powers. It is possible that the
same transaction could lead to an inquiry by both commissioners which
could lead to conflicting results. It is also possible that one commissioner
could feel that an inquiry is warranted into a certain transaction whereas
the other commissioner may decide that the same transaction does not war-
rant an inquiry. These scenarios are further complicated given that differ-
ent legislation exists for lobbyists and for public office holders. Different
standards exist in that legislation which results in one transaction could be
110 ADAM DODEK

absolutely in compliance with one act while at the same time in violation of
another act for the public officer holder.
Lobbyist gifts to public office holders provide a concrete and important
example. This area has long-attracted significant attention, controversy and
regulation. There have been instances when different standards have
existed for what constitutes an improper gift offered by a lobbyist to a pub-
lic office holder versus what constitutes an improper gift accepted by a
public office holder from a lobbyist. Both the monetary amount as well as
the definition may differ. At the federal level, the Commissioner of Lobby-
ing Karen Shepherd was able to address this problem through her own ini-
tiative and by applying common sense. In 2015, she amended the Code of
Conduct for Lobbyists to prohibit lobbyists from promising “a gift, favour,
or other benefit to a public office holder, whom they are lobbying or will
lobby, which the public office holder is not allowed to accept” (Shepherd 2015:
6). Commissioner Shepherd also adopted the definition of “gift” used by
the Conflicts of Interest and Ethics Commissioner for public office holders
(https://lobbycanada.gc.ca/eic/site/012.nsf/eng/01183.html). This makes
eminent sense because it provided for the same definition of “gift” for both
donors and recipients. The common sense approach adopted by Commis-
sioner Shepherd attempted to address a system design flaw in the drafting
of different pieces of legislation which regulate different aspects of the
same conduct.

Should the same integrity officer be responsible both

for advisory and enforcement issues or should these
functions be separated? There are advantages and dis-
advantages to each approach

The second fault line is between a unitary and a dual model for integrity
officers. Should the same integrity officer be responsible both for advisory
and enforcement issues or should these functions be separated? There are
advantages and disadvantages to each approach.
Separating the advisory and enforcement functions allows for more nat-
ural justice; that is, the same official is not responsible for both making a
ruling as well as enforcing it. For example, the City of Calgary has chosen
to create separate offices of Ethics Advisor and Integrity Commissioner
(http://www.calgary.ca/citycouncil/Pages/Integrity-Ethics-Roles.aspx).
The Ethics Advisor provides advice and guidance to members regarding
legal and reputational risk and provides advice to Council members gener-
ally. She may also assist in the resolution of complaints about the conduct
of a Council member referred to her by the Integrity Commissioner.3 The
Integrity Commissioner receives complaints about members’ conduct and
PUBLIC SECTOR ETHICS 111

decides how to deal with them. His options include dismissing the com-
plaint; further investigation and/or adjudication; or referring it to the
Ethics Advisor for resolution. He makes recommendations to Council on
the appropriate consequence or sanction for improper conduct (http://
www.calgary.ca/citycouncil/Pages/Integrity-Ethics-Roles.aspx).4
In contrast, the City of Toronto’s Integrity Commissioner fulfills both
advisory and investigatory functions. This provides for greater efficiency.
The Integrity Commissioner provides advice on the code of conduct, con-
ducts investigations and adjudicates complaints regarding possible viola-
tions of that code. However, as Toronto’s Integrity Commissioner has
acknowledged, there is an inherent conflict when an integrity commis-
sioner rules on a complaint regarding a matter that he or she has given
advice about. This model is much more prevalent than the City of Calgary’s
bifurcated model. There are advantages and disadvantages to both.

The Honourable Frank Iacobucci has stated that “to

deal with ethical issues without a framework is likely
to lead to ad hoc decision making, inconsistency, and
ultimately unfairness” (Institute of Public Adminis-
tration of Canada 2016: 17)

Finally, concerns with multiple offices exist not only for what functions
they exercise but also over whom they exercise jurisdiction. Many ethics
commissioners have jurisdiction over public office holders which include
elected officials, political appointees and public servants. There are differ-
ent considerations for the regulation of each category. This does not neces-
sarily require different officials regulating their conduct (as was the case in
Ontario until the 2000s when there were three separate offices) but it does
require different sensitivities.
For all of the above, a number of different factors are relevant: resource
and budget issues; efficiency; the need for information sharing; privacy
concerns; and the development of each office’s expertise, capacity and rep-
utation. There is no single “right” model. Each jurisdiction has to attempt
to balance these and other considerations in designing an effective account-
ability/ethics regime.

Conclusion
The Honourable Frank Iacobucci has stated that “to deal with ethical
issues without a framework is likely to lead to ad hoc decision making,
inconsistency, and ultimately unfairness” (Institute of Public Adminis-
tration of Canada 2016: 17). Mr. Iacobucci was speaking of the need for
112 ADAM DODEK

ethical rules and regulations but his comments equally apply to the need
for an institutional framework. This article has addressed some of the
challenges in the current institutional frameworks and possible avenues
for reform. The institutional frameworks for public accountability offices
in Canada are relatively young and still in their early stages of develop-
ment. The next twenty years will be critical for their maturation and
institutionalization.

Notes
1 For the purposes of this article, I exclude the office of the position of Auditor General
which has a long history in Canadian public administration.
2 See Members’ Integrity Act, 1994, SO 1994, c 38 and Lobbyists Registration Act, 1998, S.O.
1998, c. 27, Sched. Ontario’s Integrity Commissioner has five key areas of responsibility:
1) MPP Integrity; 2) Expenses Review; 3) Ministers’ Staff Ethical Conduct; 4) Ontario
Public Service Disclosure of Wrongdoing and 5) Lobbyists Registration. See Ontario,
Office of the Integrity Commissioner (http://www.oico.on.ca/).
3 The current Ethics Advisor for the City of Calgary is Professor Alice Woolley of the Uni-
versity of Alberta’s Faculty of Law (http://www.calgary.ca/citycouncil/Pages/Integrity-
Ethics-Roles.aspx#biographies).
4 The current Integrity Commissioner for the City of Calgary is the Honourable Allen Sula-
tycky, a former judge of the Court of Queen’s Bench of Alberta. (http://www.calgary.
ca/citycouncil/Pages/Integrity-Ethics-Roles.aspx#biographies).

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