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Federal Accountability Action Plan, April 2006

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Message from the Prime Minister of Canada

Prime Minister Stephen HarperCanadians have said they want us to turn over a new leaf in the way we do business in Ottawa. Canadians want to be able to trust their federal government, and know that it is accountable.

Today we are delivering on the first of our five priorities by introducing the Federal Accountability Act and its companion Action Plan. Our plan will:

These measures signal a significant change in how federal politics and government will work in Canada. Canadians understand this priority, and they have said they want us to deliver on our other key priorities:

Turning over this first leaf—the Federal Accountability Act—is my government's commitment to delivering the good, clean government that Canadians deserve and expect.

The paper version was signed by

The Right Honourable Stephen Harper
Prime Minister of Canada


Message from the President of the Treasury Board of Canada

President of the Treasury Board John BairdOn February 6, 2006, the Prime Minister asked me to deliver on our government's commitment to introduce the proposed Federal Accountability Act in the House of Commons as our first major piece of legislation.

I am proud of the efforts of all of my colleagues, my Parliamentary Secretary Pierre Poilievre, and public servants across government—from policy specialists to legal drafters—who have made this possible.

Thanks to this collaboration, we are introducing a solid piece of legislation and a clear plan of action that address every element of our platform, and more. The Federal Accountability Act and companion Action Plan is about making everyone more accountable—from the Prime Minister to parliamentarians, from public-sector employees to all Canadians and businesses who receive government funding.

Canadians expect no less. Accountability is the foundation on which Canada's system of responsible government rests. It is key to assuring Parliament and Canadians that the Government of Canada is using public resources efficiently and effectively, and that it answers for its actions.

In developing this Act for the consideration of Parliament, and the Action Plan, we have used the most effective ways, both legislative and non-legislative, to meet our commitments. We have taken steps to ensure that the proposed changes do not discourage individuals and organizations from doing business with government. And we have included measures to simplify and streamline rules so that government functions more efficiently.

This is an important undertaking—one that will require the commitment and dedication of parliamentarians and public servants alike. I am confident that, together, we can rebuild the confidence and trust of Canadians.

The paper version was signed by

The Honourable John Baird
President of the Treasury Board of Canada


Highlights

Through the Federal Accountability Act and Action Plan, the Government of Canada is bringing forward specific measures to help strengthen accountability and increase transparency and oversight in government operations. The comprehensive Action Plan includes a proposed Federal Accountability Act, supporting policy and other non-legislative measures, and a draft bill to amend the Access to Information Act.

Through this Action Plan, the Government will:

This Action Plan strikes an appropriate balance between oversight and flexibility. The Government of Canada will strengthen and streamline its management policies and consult with stakeholders on reducing barriers that inhibit access to government. It will:

Table of Contents



Introduction

Flag of CanadaAccountability is the foundation on which Canada’s system of responsible government rests. A strong accountability regime assures Parliament and Canadians that the Government of Canada is using public resources efficiently and effectively. It also promotes ethical practice—actions undertaken in government must be motivated by the public interest and carried out in accordance with legislation and policy. Effective accountability also means that those who manage public resources must be prepared to report openly on results achieved.

In a culture of accountability, roles and responsibilities are clear so that people know what is expected of them and answer for their performance; appropriate rewards for good performance are in place; and there are swift consequences in cases where rules are knowingly broken. Furthermore, a high degree of transparency makes government more accountable, and is vital to the effective participation of citizens and organizations in developing public policy.

Canadians have every right to expect that public-office holders and public-sector employees will be guided by the highest standards of ethical conduct. Recent political scandals—notably those concerning government sponsorship and advertising activities—have contributed to a further erosion of Canadians’ trust and confidence in government, and have brought issues of accountability, transparency, and integrity to the forefront of public discussion and debate.

This Action Plan represents the Government of Canada’s response to those concerns. It is a blueprint for more accountable, open, and ethical government.

In its pursuit of greater effectiveness and accountability, the Government has made sure that the measures contained in this Action Plan strike an appropriate balance between oversight and flexibility. It has recognized that, within this new accountability regime, the public service must maintain its capacity to deliver important programs to Canadians efficiently and effectively. Accordingly, the Government will streamline its management policies to replace superfluous controls and rules that hinder the effectiveness of the public service, and will consult with stakeholders on ways to reduce barriers that inhibit access to government.



Reforming the financing of political parties

Delivering on our commitment

  • New limits on individual donations to parties or candidates
  • A ban on contributions from corporations, unions, and organizations to parties or candidates
  • A longer period to prosecute violations under the Canada Elections Act

Why we are doing this

The Canada Elections Act governs campaign donations and the financing of political parties and candidates in Canada. The law ensures transparency and regulates the financial relations and operations of political parties and candidates. However, more needs to be done to rebuild public confidence in the integrity of the democratic process, and to ensure that influence cannot be bought through political donations. Donations from corporations, unions, and organizations are of particular concern, since they currently allow for a contribution of funds from unknown original sources.

The Government of Canada will toughen the laws around the financing of political parties and candidates to reduce the opportunity to exert influence through large donations.

Quebec, Manitoba, the United States, and France are a few of the jurisdictions that ban donations by corporations, unions, and organizations.

The Federal Accountability Act will:

What this means for Canadians

These changes will increase transparency, reduce opportunities to influence politicians with contributions, and help Canadians feel more confident about the integrity of the democratic process. They will level the playing field among individual contributors, and encourage political parties to engage the electorate more directly.



Banning secret donations to political candidates

Delivering on our commitment

  • A ban on candidates accepting gifts that might be seen as influencing them
  • A ban on transferring trust-fund money to candidates or political parties
  • Powers for the new Conflict of Interest and Ethics Commissioner to order that trusts not be used for political purposes or be wound up

Newfoundland, Nova Scotia, New Brunswick, Ontario, Saskatchewan, and Alberta expressly regulate the use of trust funds in the electoral process. The level of regulation ranges from disclosure to mandatory termination.

Why we are doing this

While campaign donations are regulated, riding associations can still give large amounts of campaign money to candidates through trust funds. The Government of Canada will close loopholes in the current election laws by applying new restrictions on the use of trust funds and the receipt of gifts by candidates for federal political office.


The Federal Accountability Act will introduce the following changes:

What this means for Canadians

These changes will enhance public confidence in the electoral process by banning the use of trust funds to finance a candidate’s campaign. Greater transparency and fairness regarding political financing will be the result. The Government will heighten disclosure requirements regarding the personal finances of Members of Parliament, and hence reduce the risk of their holding problematic financial interests. These measures will allow Members of Parliament to hold legitimate financial instruments that do not influence their elected positions. 



Strengthening the role of the Ethics Commissioner

Delivering on our commitment

  • A new Conflict of Interest Act
  • A new Conflict of Interest and Ethics Commissioner with powers to fine violators and consider public complaints
  • A ban on voting by ministers on matters connected to their business interests
  • An end to the use of “venetian blind” trusts

"These measures will create a strong conflict of interest and ethics regime to help build public confidence in our system of government and parliamentary institutions."

Why we are doing this

Canadians expect elected representatives and public-office holders to make decisions in the public interest, without any consideration of personal gain. Public-office holders must perform their official duties and arrange their private affairs in a manner that will avoid real or perceived conflicts of interest.

The Federal Accountability Act will:

The Government will articulate ethical guidelines for all public-office holders, including ministers, through a revised edition of Accountable Government: A Guide for Ministers that will include guidelines for political activities.

The Office of the Conflict of Interest and Ethics Commissioner will be responsible for administering the Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Code for Senators. The Commissioner will provide confidential opinions to Members of Parliament and advice to public-office holders on any matter respecting their obligations under these Codes, and will conduct inquiries on behalf of Parliament on questions of compliance with them.

The Government would welcome the opportunity to work with Members of the House of Commons and with Senators to enshrine their respective conflict of interest codes into law.

What this means for Canadians

These measures will create a strong conflict of interest and ethics regime to help build public confidence in our system of government and parliamentary institutions. By enshrining the Conflict of Interest and Post-Employment Code for Public Office Holders into law, the Government will ensure that future Prime Ministers abide by a consistent set of rules.



Toughening the Lobbyists Registration Act

Delivering on our commitment

  • A five-year ban on lobbying for ministers, ministerial staffers, and senior public servants after they leave office
  • A ban on the payment and receipt of success or contingency fees
  • Requirements that contacts with senior public-office holders be recorded
  • A new, independent Commissioner of Lobbying with a strong mandate to investigate violations under the new Lobbying Act and Lobbyists’ Code of Conduct
  • A longer period under which lobbying violations can be investigated and prosecuted

There are more than 4,700 lobbyists registered with the Government of Canada- approximately 700 are individual consultant lobbyists, with the remainder representing 270 corporations and 375 organizations.

Why we are doing this

Individuals, organizations, and businesses have the right to communicate with decision makers to provide them with information and views on issues that are important to them. Lobbying is a legitimate part of our democratic system, but it must be done ethically and transparently. It is important that Canadians have the opportunity to know who is lobbying public-office holders, and in what context.

The current Lobbyists Registration Act provides for the public registration of individuals who are paid to communicate with public-office holders about government decisions. All information collected under the Lobbyists Registration Act and its regulation is a matter of public record. The objective of the registration system is to ensure that the general public and public-office holders know who is being paid to communicate with public-office holders regarding government decisions.

Parliamentarians and others, however, have identified weaknesses with the Lobbyists Registration Act. It has been noted, for example, that compliance with registration requirements is low, that the information disclosed is insufficient, and that the Registrar lacks the necessary independence, powers, and resources to conduct effective investigations of possible infractions under the Lobbyists Registration Act. Together, these factors have increased perceptions of conflict of interest in the relationships between public-office holders and lobbyists, and have raised concerns that privileged access to government is reserved for a chosen few.

The Federal Accountability Act will introduce the following changes:

What this means for Canadians

These changes will give the Commissioner of Lobbying the independence and necessary powers to ensure that lobbying is done in a transparent and ethical way. Canadians will have easy access, through the Internet, to information about lobbying activities. They will be reassured that former senior public-office holders do not use their personal connections to obtain special favours from government once they leave office, and that conflict of interest situations do not arise while they hold office. These changes will ensure that recipients of taxpayer money do not use it to reward lobbyists, and that unregistered lobbyists are effectively investigated and prosecuted.



Ensuring truth in budgeting with a Parliamentary Budget Authority

Delivering on our commitment

  • A new Parliamentary Budget Officer to support Members of Parliament and parliamentary committees with independent analysis of economic and fiscal issues
  • Quarterly updates of government fiscal forecasts from the Department of Finance

In both the United States and the Netherlands, independent budget agencies play an important role in formulating budget projections.

Why we are doing this

Improving the transparency and credibility of the Government’s fiscal forecasting and budget planning process is a fundamental step in making it more accountable to Parliament and to Canadians. Parliamentary committees should have access to independent, objective analysis and advice on economic and fiscal issues, supported by the timely provision of accurate information from departments and agencies.

The Federal Accountability Act will introduce the following changes:

In addition, we will introduce the following measures:

What this means for Canadians

These changes will increase transparency in the Government’s fiscal planning framework, and will enable Parliament to better hold government to account.



Making qualified government appointments

Delivering on our commitment

  • A consistent appointment process for Agents and Officers of Parliament with a meaningful role for Parliament
  • A new Public Appointments Commission to oversee appointments to agencies, boards, and commissions
  • An end to priority treatment for ministerial aides when they apply for public-service positions

"These reforms will assure Canadians that the appointments of Agents and Officers of Parliament are approved by both Houses."

Why we are doing this

At present, legislative provisions that govern the appointment of Agents and Officers of Parliament are uneven and do not fully respect Parliament in the process. The appointment process for agencies, commissions, and boards is not as transparent or as merit-based as it could be. Furthermore, favoured treatment to ministerial staffers in filling public-service positions undermines both the non-partisan nature of the public service and its adherence to the merit principle.

The Federal Accountability Act will introduce the following changes:

In addition, we will give the Public Appointments Commission the responsibility to:

What this means for Canadians

These reforms will assure Canadians that the appointments of Agents and Officers of Parliament are approved by both Houses; that government appointments reward merit while respecting the values of fairness and openness; and that the potential for politicizing the public service is reduced.



Cleaning up the procurement of government contracts

Delivering on our commitment

  • A legislated commitment to fairness, openness, and transparency in the procurement process
  • Inclusion of integrity provisions in all government contracts
  • A Procurement Auditor to review procurement practices on an ongoing basis
  • A Code of Conduct for Procurement

"The Government of Canada is committed to taking appropriate measures to promote fairness, openness and transparency in the bidding process for contracts with Her Majesty for the performance of work, the supply of goods or the rendering of services."

-proposed Federal Accountability Act

Why we are doing this

In carrying out its programs and providing services to Canadians, the Government of Canada is one of the largest purchasers of goods and services in the country. It is important that the bidding process for government contracts, including those for polling and advertising, be fair, open, and transparent.

The Federal Accountability Act will introduce the following changes:

In addition, we will:

What this means for Canadians

Through these measures, the Government will ensure that the procurement process is free of political interference, and that a clear process is in place to address complaints from potential suppliers. It will also provide greater opportunities for small vendors and vendors in all regions of Canada to compete for government contracts.



Cleaning up government polling and advertising

Delivering on our commitment

  • A requirement to publicly release, in writing, polling findings within six months
  • A legislated commitment to fairness, openness, and transparency in the procurement process for advertising and public opinion research

"In 2004-2005, 621 POR  [public opinion research] projects were initiated by the government and coordinated through PWGSC for a contract value of $29 million, using the services of 74  research firms."

-Public Opinion Research Annual Report, 2004-2005 Public Works and Government Services Canada

Why we are doing this

The Government of Canada uses public opinion research and advertising to listen to and communicate with Canadians. They are vehicles through which government captures public awareness and concerns, maintains focus on the needs of citizens, and reaches Canadians with information on its programs and services.

Recent political scandals regarding sponsorship and advertising activities, however, have raised legitimate concerns about the transparency, fairness, and value for money of the procurement process in these areas. In her November 2003 report, the Auditor General raised concerns about lack of compliance with contracting rules; the manner in which public opinion research and advertising contracts were awarded; poor documentation; and the failure of oversight mechanisms to detect, prevent, and report violations.

The Federal Accountability Act will:

In addition, we will introduce the following measures:

What this means for Canadians

These measures will ensure value for money in public opinion research and advertising contracts, and will preclude those contracts from being awarded or used for partisan reasons or political benefit.



Providing real protection for whistleblowers

Delivering on our commitment

  • A Public Sector Integrity Commissioner with the power to enforce the Public Servants Disclosure Protection Act
  • A new, independent tribunal with the power to order remedies and discipline
  • Expanded whistleblower protection for all Canadians who report government wrongdoing
  • More public information on wrongdoing

"The public sector must foster an environment in which employees may honestly and openly raise concerns without fear or threat of reprisal."

Why we are doing this

The Public Service of Canada is a multifaceted institution staffed by professional, dedicated, and highly skilled people. Its employees play a crucial role in supporting the Government’s agenda and helping it deliver programs and services to citizens. Canadians have every right to expect that public-office holders and public-sector employees behave ethically and in accordance with their legal obligations. The public sector must, therefore, foster an environment in which employees may honestly and openly raise concerns without fear or threat of reprisal.

The Federal Accountability Act will introduce the following changes:

In addition to the new rules to encourage whistleblowing and protect those who identify wrongdoing in government, the Parliamentary Secretary to the President of the Treasury Board, Pierre Poilievre, has been asked to work on proposals for establishing a “made in Canada” regime that would allow members of the public to initiate legal action against private companies who may be defrauding the government of taxpayers’ money. Should legal action be successful, those who identified the wrongdoing may be eligible to receive damages that are imposed upon the defendants.

What this means for Canadians

These changes will help create an environment in which employees and all Canadians can honestly and openly report wrongdoing in the federal government without fear of reprisal.



Strengthening access to information legislation

Delivering on our commitments

  • Expansion of Access to Information Act coverage to include:
    • Seven Agents and Officers of Parliament: the Offices of the Information Commissioner, the Privacy Commissioner, the Commissioner of Official Languages, the Chief Electoral Officer, the Auditor General, the Public Sector Integrity Commissioner, and the Commissioner of Lobbying
    • Seven Crown corporations: Canada Post, Via Rail, the Canadian Broadcasting Corporation, Atomic Energy of Canada, Export Development Canada, the National Arts Centre, and the Public Sector Pension Investment Board
    • Three foundations: Canada Foundation for Innovation, Canada Foundation for Sustainable Development Technology, and the Canada Millennium Scholarship Foundation
  • A draft bill that reflects the Information Commissioner’s recommendations and a discussion paper tabled for consideration and debate

In 2004-05, the Government of Canada received 25,207 requests under the Access to Information Act.

Why we are doing this

Access to government information allows Canadians and organizations to participate more fully in public policy development and better assess the Government of Canada’s performance in order to hold it to account. The Government must instil the public trust and respect the public interest by encouraging the greatest degree of openness and transparency, while taking into account legitimate concerns such as personal privacy, commercial confidentiality, and protection of intergovernmental affairs.

The Access to Information Act became law in 1983. The legislation is based on a number of principles: that effective accountability depends on knowing the information and options available to government decision makers; that government documents often contain information vital to the effective participation of citizens and organizations in public policy development; that government is the single most important storehouse of information about our society, and that, as a public resource, this information should be made available wherever possible; that necessary exceptions to the right of access should be limited and specific; and that decisions on the disclosure of government information should be reviewed independent of government.

Since the Access to Information Act became law, much has changed in the federal government, in Canada, and around the world. Accordingly, there have been numerous calls for reform of the Access to Information Act, most recently from the Information Commissioner, who in September 2005 proposed a series of changes to the Act to the Standing Committee on Access to Information, Privacy and Ethics.

The Federal Accountability Act will introduce the following changes:

In addition, we will:

The Access to Information Act is a complex piece of legislation, with a broad constituency across many sectors of society and widely divergent views on its administration. The Information Commissioner’s proposed amendments, for example, would require more than 88 changes or additions to 46 provisions of the Access to Information Act. When the Information Commissioner appeared before the Standing Committee, he advised them that his recommendations had not had the benefit of consultations with stakeholders.

A separate process will allow the parliamentary committee to engage in a comprehensive debate in consultation with a broad range of stakeholders, and to issue a report when it reaches the end of its deliberations. This approach is necessary to balance the value of transparency with the legitimate interests of individuals, other governments, and third parties in the security and confidentiality of their dealings with government.  It will also allow for diverse views to be heard, and for the resulting legislation to find broad support after comprehensive analysis and full debate.

What this means for Canadians

By expanding the coverage of the Access to Information Act, the Government will become more transparent and more open. It will provide Canadians with access to more information from Crown corporations, Agents of Parliament, and government-funded foundations. At the same time, the Government will explore ways to further strengthen access to information legislation in consultation with parliamentarians and Canadians to ensure that their concerns receive careful attention. Doing so will ensure a measured approach to access reform that will allow the Government to widen access while mitigating costs and unintended consequences on stakeholders, partners, and government programs.



Strengthening the power of the Auditor General

Delivering on our commitments

  • New powers for the Auditor General to audit individuals and organizations that receive federal money
  • Ongoing departmental reviews of granting programs enshrined in law
  • An independent blue-ribbon panel to identify barriers to access for recipients of government grants and contributions programs

The federal government spends some $26 billion per year on grants and contributions to individuals, companies, and non-governmental organizations.

Why we are doing this

One of the most important roles of Parliament is to hold the government to account for its use of taxpayers’ dollars. To do this effectively, parliamentarians need objective and fact-based information about how well the government raises and spends public funds. The Auditor General is an independent and reliable source of such information. The Auditor General audits federal departments and agencies, most Crown corporations, and many other federal organizations; reports up to four times a year to the House of Commons on matters that the Auditor General believes should be brought to the attention of the House; and testifies on audits before parliamentary committees.

The Federal Accountability Act will introduce the following changes:

In addition, we will introduce the following measures:

What this means for Canadians

These changes will give Canadians reassurance that their government is using their tax dollars wisely. They will strengthen the role of the Auditor General as an independent and reliable source of information about government spending. To maximize the use of taxpayer money, the Government will ensure that it roots out non-performing or irrelevant programs. Finally, these measures will enhance the ability of Canadians and organizations to access government programs and services, and ensure that third parties that receive federal funding are not faced with an unnecessary administrative burden.



Strengthening auditing and accountability within departments

Delivering on our commitments

  • Designation of deputy ministers as accounting officers
  • A clear process to resolve disputes between ministers and deputy ministers
  • Strengthened internal audit functions within departments
  • Strengthened governance structures in Crown corporations
  • Tougher penalties for fraudulent misuse of public funds
  • A consistent approach to promote legal and policy compliance and enforce disciplinary measures

"Independent, objective, and timely internal audit services within departments provide assurance to deputy ministers and reinforce good stewardship practices and sound decision making."

Why we are doing this

Under the doctrine of ministerial responsibility, ministers are responsible and accountable to Parliament for all powers vested in them, whether by legislation or otherwise. With respect to their departments, ministers are responsible to Parliament and the Prime Minister for their own actions and those of their officials, whether those actions pertain to policy, operations, or departmental administration. In particular, they are responsible for the management and direction of their departments. This accountability must be supported by appropriate systems of control, including appropriate communications between ministers and deputy ministers, who themselves have responsibilities for departmental management. It is vital that, within the framework of the minister’s overall responsibilities and his or her accountability to Parliament, the roles and responsibilities of deputy ministers are clear.

Independent, objective, and timely internal audit services within departments provide assurance to deputy ministers and reinforce good stewardship practices and sound decision making. They also enable Treasury Board to focus on Government-wide strategic matters dealing with risk.

The Federal Accountability Act will introduce the following changes:

In addition, we will introduce the following measures:

What this means for Canadians

For Canadians, these measures will strengthen accountability and ensure that all government officials, from ministers to employees, are aware of their responsibilities under law and government policy and of the consequences of breaching them. They will clarify the roles and responsibilities of deputy ministers and, together with a stronger internal audit capacity, help ensure that departments are well managed to meet the needs of Canadians. Finally, they will strengthen enforcement of government financial guidelines and toughen penalties for the misuse of taxpayers’ money.



Creating a Director of Public Prosecutions

Delivering on our commitments

  • A new, independent Director of Public Prosecutions to prosecute criminal offences under federal law

"The Office of the Director of Public Prosecutions will have independence to pursue prosecutions under federal law and will report to Canadians on its performance."

Why we are doing this

It is important for transparency and for the integrity of the federal justice system that prosecutions under federal law operate independently of the Attorney General of Canada and of the political process. Crown counsel within the Federal Prosecution Service of the Department of Justice and legal agents currently prosecute federal offences throughout Canada, and provide legal advice to investigative agencies and government departments in matters of criminal law. The creation of the Office of the Director of Public Prosecutions will make absolutely clear the independence of criminal prosecutions from political influence by formally separating the Federal Prosecution Service from the Department of Justice.

The Federal Accountability Act will:

In addition, we will introduce the following measures:

What this means for Canadians

The new federal Office of the Director of Public Prosecutions model reflects the best features of similar offices that currently exist in three Canadian provinces (British Columbia, Nova Scotia, and Quebec) and in several countries around the world, including the United Kingdom, Australia, and Ireland. The Office of the Director of Public Prosecutions will have independence to pursue prosecutions under federal law and will report to Canadians on its performance.



Conclusion

The Federal Accountability Action Plan is about strengthening accountability and integrity in government. It is about reassuring Canadians that the Government of Canada is working in their best interests.

Taken together, the legislative and policy measures outlined in this Action Plan are far-reaching and significant. The Action Plan will do the following:

As a final measure, the Government of Canada remains committed to ratifying the United Nations Convention Against Corruption as soon as possible. This Convention is the first global treaty of its kind, and is expected to become the most important and widely applied international instrument to fight all forms of corruption, particularly as they affect the developing world. Canada has played an active role in developing the Convention, and is in an excellent position to promote compliance with the accountability and transparency measures it contains.

Above all, the measures detailed in this Action Plan will promote a culture of accountability in government. They will help restore public confidence in government, and will deliver the honest government that Canadians expect and deserve. As it proceeds, the Government will work with parliamentarians, the public service, Agents and Officers of Parliament, and Canadians to implement this Action Plan.


Return to footnote reference 1. This process will apply to the Auditor General, Information Commissioner, Privacy Commissioner, Commissioner of Official Languages, Public Sector Integrity Commissioner, Conflict of Interest and Ethics Commissioner, and Commissioner of Lobbying.

Return to footnote reference 2. The appointment of the Chief Electoral Officer is made by resolution of the House of Commons only.

Return to footnote reference 3. Exemptions under the Access to Information Act related to issues such as national security and
federal/provincial affairs will continue to apply.

Return to footnote reference 4. Exemptions and exclusions under the Access to Information Act related to issues such as national security and federal/provincial affairs will continue to apply.

Return to footnote reference 5. This authority would not extend to transfers or transfer payments to other governments or international organizations, or to recipients that have received, in total, less than $1 million over any five consecutive fiscal years. Other governments and international organizations—including foreign governments, provinces, local, regional, and municipal governments, and self-governing First Nations—will therefore be exempted from these audits.


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