Report on Governance Structures for Values and Ethics

In 2005, at the request of the Community of Senior Officials for Values and Ethics, the directorate that was responsible for liaison, evaluation and accountability in what was then the Office of Public Services Values and Ethics (OPSVE) undertook a study of departmental practices in managing values and ethics in the federal public service. (Please note that OPSVE has since been integrated into the Office of the Chief Human Resources Officer (OCHRO)). The study provides departments and agencies, who are either just starting out or who are re-evaluating their own governance structures, with guidance on governance models and considerations to assist them in making informed decisions about what might work best within their organizations.

OCHRO does not endorse any particular governance or structural model for implementing values and ethics in federal organizations. We also recognize that the example organizations that appear in this report may have changed their governance structures over time. Indeed, research to date reveals that it is not the particular structure or governance of a departmental office of Values and Ethics that contributes most to a high level of values and ethics performance, but the degree to which day-to-day management practices that promote organizational Values and Ethics are integrated into departmental approaches to doing business that has the greatest influence on outcomes.

Table of Contents

1.0 Introduction

Governance refers to the processes and structures that any organization uses to direct and manage its general operations and program activities. Features of Governance include but are not limited to:

  • Strategic Planning – plans, objectives, program and policy coherence
  • Leadership – championing the vision and demonstrating exemplary behaviour with respect to values and ethics
  • Design – organization structure that facilitates decision-making, communication and meeting program objectives
  • Stewardship – management accountability for oversight, assessment, direction and appropriate resourcing and reporting on the values and ethics program
  • Risk Management – identifying, mitigating and managing values and ethics risks

The Directorate of Liaison, Evaluation and Accountability (DLEA) in the Office of Public Service Values and Ethics (OPSVE) at the Public Service Human Resources Management Agency (PSHRMAC) undertook a study of governance structures and practices in managing values and ethics (V&E) in the federal public service. The study was commissioned to provide departments and agencies, who are either just starting out or who are re-evaluating their own governance structures, with guidance on governance models and considerations to assist them in making informed decisions about what might work best within their organizations. The study involved the development of profiles of the 'as-is' or current governance structure and practices in seven departments in the federal government and one private sector organization.

The public service values and ethics program areas studied included those related to the Values and Ethics Code for the Public Service such as the Prevention and Resolution of Harassment in the Workplace Policy, the Internal Disclosure of Information Concerning Wrongdoing in the Workplace Directive, the Workplace Wellbeing policies, and the Informal Conflict Management System (ICMS).

1.1 Distinction between values-based and compliance–based programs

All of the ethics offices of public service organizations profiled herein have adopted a values-based ethics program. There is often confusion concerning how values-based ethics programs differ from compliance. Often the programs are contrasted as rules versus values, as if rules and values were mutually exclusive.Footnote 1  To avoid confusion at the outset it may be worthwhile to distinguish between compliance-based and values-based ethics programs.

The purpose of compliance programs is to prevent unlawful conduct by ensuring employees conform to externally imposed rules. Compliance-based programs may introduce additional rules to ensure behavior conforms to law and regulation. Weaver and TrevinoFootnote 2 note the following characteristics associated with compliance-based programs:

  • Development and communication of clear policies and guidelines to ensure compliance;
  • Education to ensure awareness of rules;
  • Management direction and supervision;
  • Monitoring of employee behavior; and
  • Sanctions for non-compliance.

All organizations are constrained by law and social expectations of ethical behavior. Compliance-based programs address the first constraint but not the latter. Compliance-based programs govern compulsory behavior, i.e. behavior determined by law. Values-based programs may choose to address compulsory behavior but their main focus is on discretionary behavior.  Values oriented ethics programs are built on a foundation of pre-existing organizational functions, which ensure compliance. A values-based program, as well as addressing discretionary behavior, encourages an independent critique of the decision process. In supporting employees, values-based programs try to create a safe zone for employees to discuss ethical issues and introduce ethical concerns into decision-making.

Values-based programs are generally associated with:

  • Development of higher standards of behavior through shared values;
  • Encouragement of dialogue to interpret shared values;
  • Enabling responsible conduct by providing support for employees' ethical aspirations; and
  • Managerial responsibility for implementation (Weaver & Trevino, 1999).

Both compliance and values-based programs are associated with the following outcomes:

  • Reduced unethical behavior;
  • Ethical advice seeking;
  • Awareness of ethical issues; and
  • Perceptions of better decision-making (Weaver & Trevino, 1999).

Although Weaver and Trevino do not qualify their findings, it should be noted that the four outcomes described above vary in accordance with an ethics program. For example, in a compliance-based program all of the findings relate to compulsory behavior. In a values-based program all of the findings relate to both compulsory and discretionary behavior.

The following outcomes are only associated with a values-based program:

  • Commitment to the organization;
  • Employees more likely to believe that their integrity remains intact; and
  • Willingness to deliver bad news (Weaver & Trevino, 1999).

Enhanced organizational commitment is correlated with increased organizational effectiveness. Hence we would expect to find values-based ethics programs associated with high performance organizations. A willingness to deliver bad news suggests that disclosure of unethical conduct is more likely within a values-based ethics program.

In any event, all of the public service organizations profiled herein would be described as utilizing a values-based ethics program (or in one case a values-based ethics initiative). There are, nonetheless, differences in the degree to which compliance functions are subsumed within the ethics offices.

1.2 Approach

The Office engaged Peter Hadwen Consulting Inc to conduct the study. Peter Hadwen, Stephen Maguire, and Dominique Dennery collected the data. Peter Hadwen and Stephen Maguire are co-authors of this report. The approach focused on developing profiles of the following seven government departments and one private sector company:

  • Department of National Defence (DND);
  • Department of Foreign Affairs and International Trade (DFAIT);
  • Health Canada (HC);
  • Public Works and Government Services Canada (PWGSC);
  • Royal Canadian Mounted Police (RCMP)
  • Correctional Service of Canada (CSC);
  • Library and Archives Canada (LAC); and
  • Nexen Inc. (private sector).

The profiles depict the "as is" or current model of the governance structures and practices of each values and ethics program. They do not evaluate the effectiveness of each model. The profiles provide a graphical depiction of the current values and ethics structure of each profiled organization supported by a text description of the following:

  • Evolution of the governance model to the present day;
  • Organization structure and responsibilities of the unit responsible for the values and ethics program;
  • How the governance model generally works;
  • A detailed description of current activities within the governance model; and
  • The factors for success in ensuring the model's governance structures and practices are successful in integrating values and ethics in the working culture of the organization.

Key governance structures and practices covered in the profiles include:  Leadership, plans, policies and guidelines, communications, learning, staffing, staff performance evaluation, tools, organization, committees/working groups, risk management, performance measurement and reporting, and recourse mechanisms.

The profiles were developed through a variety of research techniques including:

  • Forty interviews with officials from the eight organizations studied (see Appendix 1 for the interview guide);
  • Five focus groups in different organizations with operational managers (see focus group guide in Appendix 2); and
  • Review of documentation provided by each organization profiled.

Using the profiles, it was possible to develop a summary chapter, which identified some common features and factors of success for the implementation of values and ethics governance in the public service.

1.3 Qualifications

This report is a qualitative depiction of governance based on the expertise of officials involved in values and ethics programs. It is not an evaluation of effectiveness. While this report does not claim to be exhaustive, it has been possible to develop general observations from comments consistently expressed by interviewees and in focus groups, and from a comparison of facts and governance features in documentation provided by participating organizations.

1.4 Organization of report

The first eight sections of the report contain the profiles of each organization profiled in this study (DND, DFAIT, HC, PWGSC, RCMP, CSC, LAC, Nexen Inc.). The final section provides a synthesis of the similarities and lessons learned from the eight profiles.

2.0 Department of National Defence(DND)

Figure 1: Department of National Defence (DND) Governance Model for Values and Ethics
Governance Model. Text version below:
Figure 1 - Text version

The DND Governance Model depicts a decentralized structure headed by the DM/Chief of the Defence Staff whose roles is that of exemplary behaviour, overt support, resourcing and setting the tone. Below the DM/Chief is the Chief of Review Services (CRS) who oversees the Director of Defence Ethics Program (DEP) and 3 additional directors: Audit, Evaluation and Special. The CRS also chairs the Ethics Advisory Board which has a consultative role among Ethics Coordinators.

The Defence Ethics Program (DEP) itself – led by a Director – provides support to 20 ethics coordinators and 20 L1s (authority structures) within DND.

Key Outcomes of the DEP (Vision): Canadian Forces and DND become organizations and cultures of integrity with highly internalized ethical values consistent with Canadian and Defence values.

Scope: Mirrors requirements of the Code.

Primary Activities: Advice on ethics, referral, conflict of interest, post-employment, awareness building (e.g., presentation), collecting L1 plans, assessment of risk, training of ethics coordinators (future), development and review of training tools, keeping current in ethics research.

The model identifies linkages inside the organization including:

  • Harassment – referrals
  • Alternate Dispute Resolution – minimal
  • Disclosure – referrals provided
  • Political Activity – work with HR Civilian
  • Canada Defence Academy – ensure ethics and values is part of the curriculum
  • Director, Human Resources Research and Evaluation (ethical climate surveys)

The model also identifies linkages outside the organization with the Canada School of the Public Service for the purpose of providing entry level courses.

Governance Model

"Integrating values and ethics in the organization culture"

Evolution of DND's ethics model

The development of a Defence ethics program began in 1994 and was formally authorized in 1997. The directorate of the Defence Ethics Program (DEP) started with a theoretical foundational document (Fundamentals of Canadian Defence Ethics) which identified ethical principles and values appropriate for the Canadian Forces and its civilian employees (Statement of Defence Ethics) and which are also congruent with broad overarching Canadian values as well as public service values expressed in the Code of Values and Ethics for the Public Service. Beginning with these values and a clear goal to shape organizational ethical culture the office of the DEP created elements of an ethics program framework; objectives, resources, processes, and authority structures responsible for implementation of action plans. The directorate of the DEP was originally conceived to be a centre of expertise providing support to twenty different authority structures (known as L1s). All of the L1s have been mandated by the DEP to develop and implement their own ethics program consistent with the strategic direction of the DEP. This decentralized approach concedes operational authority to fiercely independent business lines. The directorate of the DEP continues to affect change by partnering with the L1s.

The DEP is moving towards exercising more influence with the different authority structures. For smaller L1s, limited in resources, the DEP will be a more active partner in development and implementation of plans. Larger L1?s may choose to remain autonomous provided certain conditions (currently under negotiation) are satisfied. The next stage of the development of the DEP model (Level 2) will focus on:

  • Enhancing the oversight process so that analysis, feedback and recommendations can be provided to the leaders of the department and the forces about how structures, process, and performance may be improved.
  • Moving the focus of learning and other interventions toward reaching the individual. As one interview phrased it: How do we provide resources to the employee so that he/she may better understand what the expectations of values and ethics mean to my day-to-day job? There should be more direct contact with the individual and the development of communications products or services that use plain language. The goal is also to create more consistency and economy in communications and learning.

In the longer term the DEP hopes to develop a more ?holistic? approach (Level 3) consisting of oversight and guidance from the DEP in areas of policy and procedure, including in civilian areas such as procurement, finance and HR.

Outcomes of the defence ethics program

  • Maintain public trust in the performance of its mandate
  • Develop and sustain an ethical climate supportive of ethical decisions and actions
  • Encourage individuals to act on values consistent with Canadian society and the Statement of Defence Ethics
  • Ensure individuals and the organization respect its obligations to the public interest and act in accordance with ethical and legal constraints.

Organization structure of the defence ethics program

The organization structure is outlined in the chart below. The Chief of Review Services is responsible for the DEP, as well as Audit, Evaluation and Special Examinations. The DEP program is designed to provide a one-stop shop that mirrors functional requirements of the Code of Values and Ethics for the Public Service (values, conflicts of interest, post employment and avenues of resolution). In the future the Office of Disclosure may be housed within the DEP.

Figure 2: Organization Structure of the Defence Ethics Program
Organization Structure. Text version below:
Figure 2 - Text version

The DEP is led by a Director of DEP at the Colonel level who oversees 5 FTEs responsible for Conflict of Interest and 3 FTEs responsible for Research and Development.

Conflict of Interest staff are represented by: an AS-7 Section Chief (strategic level review including directives); 2 AS-5s and a Chief Warrant Officer (Conflict of Interest – confidential reports and one officer reviews plans from L1s); and a CR-3 responsible for administration.

The Research and Development staff are represented by: a Major (military) and 2 AS-5s. The role of the Research and Development staff is to primarily update and upkeep materials/tools including presentation (80% upkeep, 20% development).

The budget for the DEP is estimated to be $1.1 in salary/SWE (salary wage envelope) and $6.7 million in operations and maintenance (O&M). O&M includes primary formal and dedicated training in ethics. Regarding the budget and expenditures of the Defence Ethics Program, it is extremely complex to calculate the full breadth of the program investments, including the informal dialogue/training, workshops, discussion groups, seminars, communications, as wall as a % of the overall salary costs for hundreds of Level 2 and Level 3 ethics coordinators. These types of activities have not been captured in the estimate.

Functional responsibilities of staff members

Staff members involved in conflict of interest keep a record of cases, offer advice, and record their activities. Staff members involved in research and development are responsible for the design of the ethics framework, partnering in the development of ethical survey instruments, developing decision making tools, introductory and customized training in association with the Canadian Defence Academy and the L1s, monitoring implementation of L1 ethics plans, and developing program performance measurement tools.

How the decentralized model works

There are wide differences in implementation plans. Smaller L1s may number as few as 250 people, while the largest, Land Forces Command, contains 40,000. Smaller L1s focus on mini-conferences to prompt dialogue on ethical concerns. The ethics responsibilities of an Ethics Coordinator of a small L1 are secondary to other duties. Land Forces Command, on the other hand, has a full time ethics officer, and 300 unit ethics coordinators (secondary duty). Although there are three levels of command between the army ethics officer and the Chief of Land Staff, the ethics officer, will, when appropriate report directly to the Chief of Land Staff. Unit ethics coordinators are responsible for ensuring that their unit has an ethics plan including addressing ethical risks. All ethics coordinators are chosen on the basis of their career development, a process, which ensures that future high-ranking officers will have had exposure to embedding ethics within the organization. Career progression also ensures a high turnover rate amongst unit ethics coordinators, a key factor in cultural transformation.

The Army Ethics Program (AEP) has the status of an operational order (see LFCO 21-18) which embeds ethics in the command and leadership functions of the army. A responsibility for ethics has become part of the job description of anyone in a leadership position. Explicit ethical obligations inform expectations of regular soldiers, reserves, and civilians. Every unit is responsible for offering one training day/year on ethics, a total of 40,000 training days annually. This training is in addition to ethics modules incorporated into courses offered by Director of Army Training (DAT). During these training days written feedback on ethical concerns is elicited from all participants. The feedback is passed upward in the chain of command only after being read by each command level. A frank summarized report is presented to Chief of Land Staff.

The Army Ethics Officer is engaged, with support from DEP, in developing a number of tools; training support packages for unit ethics coordinators, a two day training program for unit ethics coordinators, developing ethics modules for DAT, ethical climate surveys, performance measurement, and a help line. The army Ethics Officer has formal and informal linkages to the military police, career development, and DAT.

Program pverview: practices for integrating V&E in organization culture

Structure or process Current activities Factors for success

Leadership

The DEP reports to the Chief of Review Services who reports to the Deputy Minister and Chief of the Defence Staff.

 

Ethics training is provided to senior leadership. Ethics is embedded in command and leadership responsibilities. For example, a frank assessment of the military ethos in the army is provided in Canada?s Soldiers: Military Ethos and Canadian Values in the 21st Century.

Operational managers see support from top leadership as the most important factor of success. Support means demonstrating good ethical behaviour, providing the right tone in communications and responding to ethical situations, and ensuring resources are applied to invest in a continual refreshing of the values and ethics program.

Values and ethics should be part of an annual cycle where deputy ministers are seen to be involved in the program either through the form of an ethics conference, or a message to the troops or an ethics theme.

The leadership cadre depends on a vigorous champion for values and ethics. Senior management meetings would benefit from regular discussions of values and ethics, and the application of decision tools.? Realistic appraisals of senior leadership with respect to values and ethics are important to ensure continued improvement. Ethics and values is not a project-based decision to be taken by senior management, but an area that requires continual vigilance and attention.

Policies and guidelines

Fundamentals of Canadian Defence Ethics ?provides the theoretical and practical framework for the DEP. Duty with Honour describes the reciprocal responsibilities between the Canadian government and the Canadian forces, the duty of the military to uphold Canadian and military values, as well as the fundamental expectations the Forces have of its soldiers. The Statement of Defence Ethics is also meant to apply to civilian employees.

The DEP strikes a balance between heavy-handed observance of the letter of the law and consideration of the risk or impacts on individuals. Operational managers indicated that the interpretation of the code and guidelines requires a balance "between a strict observance and understanding of the situation."

The reputation and trust in the advisory services of DEP depends on how much they are perceived to provide an "understanding" approach.

Communications

Various communications products have been prepared including booklets (e.g., "An Ethical Relationship"), pocket cards.? A website is a key communications tool for the DEP.? L1s also maintain websites with values and ethics components and tools.

 

Greater innovation is possible in the development of remote, internet-based training and communications. This takes resources that may best be more centralized.? Investments should be made in the best practices of the private and public sectors.

Communications should focus on positive as well as risk related messages, to ensure employees can feel encouraged about any progress or successes with respect to values and ethics. Plain language and efficiencies in the use of tools such as intranet sites are needed. In large organizations a coordinated approach to using websites is needed to be both cost-effective and consistent in the information presented. Communications must continually be refreshed to find ways of making the program viewed as approachable and accessible.

Learning

Learning is a key element of the program. DEP staff review learning tools for values and ethics instruction. Staff regularly give presentations. Session guides are updated.

Training support packages and collaboration with DAT and CDA to offer ethics modules in all operational training.

An ethical decision making tool has been developed.

 

Teaching tools and training products need to cater to both civilian and military issues relating to practical day-to-day matters.? The DEP should have a strategic role with learning in vetting tools, determining the minimum learning requirements and events for L1s at all levels, and assess and redress gaps: "There should be a strategic sense of where we insert ethics training."

Training needs to be refreshed on a regular basis since ethical concerns change over time. There is a need to show adjustments in the program. There is a need to develop a yearly or two-year cycle requiring employees to receive certain training each year. If this were to occur training programs would have to be constantly refreshed/updated.

Staffing

Staffing is carried out for military and civilian personnel, with respect to values and ethics.

Values and ethics is a condition of employment, and also of performance evaluation. Competencies may need more definition with respect to the requirements for staffing and evaluation. For senior members of the DEP program a desired competency is a theoretical background in ethics.

Staff performance evaluation

Military personnel have values and ethics incorporated as an element of performance evaluation.

Operational managers identify as a key challenge the fact that a "desire to not offend undermines the ability of performance appraisals" to make an unvarnished assessment of values and ethics. A key change management tool is the incorporation of values and ethics considerations in the performance evaluations of managers down to EX minus 2 level.

Plans

Ethics coordinators in L1s must submit action plans to the senior officer of the L1 as well as to the DEP.

Ethics Unit Plans are submitted by L1s to the DEP based on a "call" by the DEP.

There is a need for a clear strategic roadmap, containing initiatives for embedding values and ethics in the organization. This should be incorporated as an element of business planning in the department.

Unit ethics plans need to be collected from all L1s and reviewed for progress against the roadmap. A greater oversight role is possible in assessing the consistency and effectiveness of the implementation of ethics plans in the L1s.

Organization

See organization structures above. This is a decentralized model relying on full or part-time ethics coordinators in each L1. The coordinators interact with part-time ethics officers at each organization level.

Operational managers believe that the values and ethics program must not appear isolated organizationally, but as an integral element of management.

For larger commands ethics coordinators should be more dedicated full-time resources. There may be alternatives for ensuring smaller L1's maintain robust ethics and values activities, such as a larger role for DEP in implementation.

Committees/ Working groups

The Ethics Advisory Board is chaired by the CRS and comprised of the ethics coordinators.

The substantive role of the advisory board is not clearly understood. It can provide a forum to discuss best practices and submit potential recommendations to a more senior level committee. There may be a need to find a receptive forum for senior management decision-making. One alternative to consider is the use of the Audit and Evaluation Committee as a forum to assess the progress of ethics initiatives; take the pulse of the organization; and establish some common objectives for the next year or two years.

Risk management

The DEP maintains a self-assessment tool that leaders can use to evaluate the ethical climate in their unit or section. Risk identification and management is also part of unit plans within the army.

Greater instruction about risk assessment is needed as part of the management process. There are ethical decision tools, but these need to be considered in relation to a framework of risk where ethical risks are identified and then approaches to mitigation addressed.

Performance measurement and reporting

The DEP has defined a performance measurement framework. Performance is measured primarily through the Defence Ethics Surveys. Land Forces Command is also developing its own ethical climate instrument.

Ethical climate surveys were conducted in 1999 and 2003 to identify gaps between expectations and the current culture.

 

An evaluation of the values and ethics program is needed to offer unvarnished advice on the relevance and success of the program at the L1 level and below. The objective of the evaluation would be to identify how the program can evolve further and to assess achievement against performance measures. The evaluation would rely on a top-down assessment through interviews and other techniques, but also a bottom-up survey. The timing should be based on a three-year cycle. The recommendations should be incorporated in L1 plans and in communications and decisions by the leadership.

Performance measures should be identified and monitored: If you are going to have an ethics program that is of value you have to have metrics to prove it is successful.

Recourse mechanisms

Disclosure and other mechanisms are in place. Members of the forces are obligated to report wrongdoing, while civilian employees are not. There is significant activity in this area. Depending on the introduction of C-11 the workload may increase.

Accessibility is a key factor of success, which requires awareness building and the ability to deal with the issues fairly, quickly and responsibly.

Other initiatives

Increase staff to put in a communications expert. DEP would benefit from having a dedicated communications office to deal with internal communications (e.g., postures, brochures and messaging)

Large departments should invest in a communications officer to keep values and ethics in the mind's eye.

3.0 Foreign Affairs and International Trade (DFAIT)

Figure 3: Foreign Affairs and International Trade (DFAIT) Governance Model
Foreign Affairs and International Trade (DFAIT) Governance Model. Text version below:
Figure 3 - Text version

The DFAIT governance model identifies two leads DMs – the DM of Foreign Affairs Canada (FAC) and the DM of International Trade (IT) with oversight for ethics and values within DFAIT. These 2 DMs jointly oversee the ADM HR who has responsibility for:

  • Organizational development, including team building
  • Employee Assistance Program
  • Informal Conflict Management System
  • Labour Relations
  • Health and Safety
  • Human Rights Complaints
  • Etc.

They also jointly oversee the Inspector General who manages the Director of Values and Ethics (to whom the DMs provide review and advice on cases), the Director of Audit and Special Investigations and the Director of Evaluation.

The Director of Values and Ethics has a direct role in:

  • Values and Ethics advice
  • Awareness
  • Training and Culture development activities
  • Harassment prevention
  • Internal Disclosure
  • Post-employment
  • Conflict of Interest

The Director also coordinates with the ADM HR.

Key Outcomes (Vision): Increased discussions on values and ethics, adherence to rules and policies, more harmonious work environment and change in culture.

Scope: Requirements of Code

Primary Activities: Advice on ethical dilemmas, case management, policy implementation, referrals to other programs, awareness building (e.g., presentation), communications and other planned activities.

The model identifies linkages inside the organization including:

  • HR, including about:
    • Coordination of cases
    • Shared training activities
    • HR Advisory Committee
  • Audit and Special Investigations on cases and participation in committee
  • Canadian Foreign Service Institute participation in training sessions and pre-posting sessions.

The model also identifies linkages outside the organization with:

  • CSPS
  • Universities
  • OPSVE
  • Partner Departments (CIC/CIDA/DND)
  • EPAC
  • Office of the Ethics Commissioner

For the purpose of:

  • V&E training
  • Learning
  • Policy and networking
  • Policy and coordination
  • Professional development
  • Order-in-Council appointments.

Governance model

"Integrating values and ethics in the organization culture"

Evolution of values and ethics model

The values and ethics work of the Department of Foreign Affairs and International Trade is led by the Values and Ethics Division (hereinafter the "Division") within the Office of the Inspector General. The Division was created on with stand-alone responsibilities for values and ethics in the department. The Division is now entering the second year of its mandate and roll out of activities, including solidifying its profile and working relationships with HR and other branches and missions in the department. This has involved decisions on the appropriate situating of responsibilities considered integral to values and ethics such as conflict of interest and harassment complaints.

Prior to this date the Human Resources (HR) Branch handled matters related to values and ethics. Ethics training was incorporated into various management courses offered by the Canadian Foreign Service Institute. The activities of the department extended to some promotional activities (distribution of the Code, an intranet link and some communications [e.g., posters]). The focus was to address complaints of alleged harassment as they arose and advice on conflict of interest as requested. The Senior Official for internal disclosure was the Inspector General.

In general terms the current role of the division is to be a centre of expertise to support all employees in developing a strong culture of values and ethics. The division handles both formal and informal harassment complaints, as well disclosures of wrongdoing. However, a proactive approach has been adopted focussed on enhancing the values and ethics culture of the department through increased investment in awareness building, training and communications.

Outcomes of the values and ethics program

  • Increase discussions on values and ethics
  • Greater adherence to rules/policies
  • More harmonious work environment
  • Better use of mechanisms for early conflict resolution
  • Increased credibility in the system
  • Change in departmental culture
Figure 4: Organization structure of the values and ethics division
Organization structure of the values and ethics division. Text version below:
Figure 4 - Text version

The values and ethics division is led by the Director and Senior Officer for Disclosure (EX-01) who oversees a team of 6 FTEs.

This team is represented by one Learning Specialist (EDS-03), 2 Harassment and Conflict of Interest Advisors (PE-04s), one Communications and Awareness Advisor (AS-01), one Management Issues Officer (AS-06) and an Assistant (AS-01). Each member of this team reports directly to the Director and Senior Officer for Disclosure.

Organization structure of the values and ethics division

The current organization structure is outlined in the chart at right. The classification and work of each officer in the division is still in transition as the division strives to respond better to the needs and strategic direction of the department.

For administrative purposes the Director reports to the Inspector General (Ex-03). The Director has access, as required, to the deputy ministers for all internal disclosures and cases. Occasionally, the Director discussed cases and disciplinary issues with the Associate Deputy Minister.

The organizational structure reflects approved responsibilities of the office for areas of activity such as harassment, internal disclosure, post-employment and Conflict of Interest (COI) cases and advice.

The organizational structure was developed to support an increasing volume of requests for advice and disclosure cases, as well as the substantial start-up requirements for awareness and other culture change activities. From a workload perspective, disclosure and policy responsibilities of the office may also increase depending on the outcome of government legislative initiatives (e.g., Public Servants Disclosure Protection Act). As such, the department anticipates that the organization structure depicted below may be subject to change in the near term.

The Budget of the Division is $1 million involving $580 in salaries and $420 O&M. Most of the O&M expenditures ($300,000) are for outside contracting of investigations (e.g., harassment complaints). The remainder is spent on travel, tools, kits and staff training (e.g., travel to missions abroad, conferences, EPAC, Universities, Canada School of the Public Service, and the Canadian Foreign Services Institute).

Functional responsibilities of staff members

The officer responsible for Management Issues and Conflict of Interest is intended to provide a vital link with the professional milieu of rotational personnel (serving back and forth internationally) and locally engaged staff in missions abroad who would be familiar with the ethical dilemmas and conflicts of interests particular to work abroad. This is a rotational position that is staffed with a Management Consular Officer (MCO) who would be familiar with policies, controls, and administration of rules at posts abroad. Harassment and Internal Disclosure Advisors provide advice and case management services for the department. The Communications and Awareness Officer oversees the development of materials and products focussed on building awareness and training staff about general values and ethics, the role of the division, and the application of the recently developed Code of Conduct for Representatives Abroad. The officer performs a liaison role supporting the training activities of the Canadian Foreign Services Institute. The Division has relied on the temporary support of a learning specialist to develop case studies and assist in training activities.

How the model of the department works

The Division performs two main functions: 1) advisory and case management services; and 2) increasing the values and ethics culture in the department. With respect to advice-giving division staff will counsel or advise an employee on the appropriate course of action. In harassment cases, if a decision is made to investigate the division will hire a third party to prepare and submit an investigation report. Division staff handle other advice and cases internally. If the report substantiates that harassment has occurred the Division will make recommendations to management on corrective and disciplinary measures, if required. Some cases may require the participation of advisors from HR (i.e. mediators/facilitators) or other organizations in the department, as well as Heads of Mission.

The inter-relationship between HR and the Division points to the general need for regular and intensive coordination about process and with respect to individual cases (albeit within the confines of confidentiality concerns). This is considered vital to the effective triage and hand-off of cases and preventing duplication in services. Duplication can occur when the same complainant seeks recourse from different organizations. Currently, coordination is occurring informally through regular bilateral meetings between the Division and HR and the participation of the Division Director in the HR Advisory Committee. Discussions have occurred about establishing a Recourse Committee covering values and ethics policy areas as well as ICMS, Employee Assistance, Staff Relations, Locally Engaged Staff (LES), and matters related to organizational "wellness".

The second level at which the model works is in enhancing the values and ethics culture of the department. The division is investing significantly in awareness building activities, training and further elaboration of the PS Values and Ethics Code. The Division has made presentations to management, staff training sessions, and retreats. An intranet site was built describing the activities of the Division. Numerous presentations and discussions have occurred at posts abroad, with geographic bureaus and at learning sessions in the department. A private telephone, fax line and e-mail conduit have been established and promoted to encourage disclosures.

Overview: practices for integrating V&E in organization culture

Structure or process Current activities Factors for success

Leadership

The Deputy Minister has announced the program and communicated support, as well as made the necessary resources available.

 

Heads of Mission are being engaged and understand their role vis-is values and ethics.

Operational managers see support from top leadership as the most important factor of success. Good leadership occurs through: enforcement, leading by example, communications, rewards and recognition, and resource allocation. Investment must occur to ensure people at all levels are in place to discuss and act on values and ethics.

A departmental values statement is being considered as a foundation for ethical considerations in the department.

Managers need to ensure they have open discussions/dialogue with staff about values and ethics dilemmas with respect to matters under the PS Code. This can occur at retreats and other staff/manager events.

Policies and guidelines

To tailor the Values and Ethics Code for the Public Service to the departmental environment the Code of Conduct for Canadian Representatives Abroad was developed and distributed. The code of conduct was distributed with a letter from the Deputy Minister to all Heads of Mission. A generic letter from the Deputy Minister is included with the Code of conduct for all employees abroad.

The Post Confirmation Form (PCF) must be signed and states that as a condition of being assigned to a mission abroad DFAIT employees and rotational staff from other departments are expected to read its contents [Code of Conduct] and abide by it.

The policy development process should incorporate ethical considerations. Any release of values and ethics statements should coincide with the distribution of a kit, supported by management commitments to conduct training and other awareness building efforts.

As is the case with security matters, staff should be required to sign a statement attesting to their understanding of and commitment to values and ethics, and codes of conduct.

Communications

Various communications products have been prepared including an intranet site, messages to all staff, and a mail out of the Code of Conduct for Canadian Representatives Abroad.

To gradually overcome the Mount Everest of cynicism about recent developments it is vital that employees understand why the program was developed and that it addresses their day-to-day concerns. This occurs not only through good words, but also through investment in the promotion of ongoing dialogue and awareness building. Employees must be convinced that the program is "here and staying." Employees need to fully understand the role and services available from the Division.

Communications products must be regularly disseminated to keep the values and ethics program visible and fresh.

Learning

Learning is a key element of the program. Presentations have been made to various learning events and at management and staff retreats. The Division works closely with the Canadian Foreign Service Institute. Values and ethics form a key part of all pre-posting training.

Teaching tools and training products need to cater to the needs of all types of staff (rotational, non-rotational and local staff engaged at missions abroad). Learning efforts need to include dialogue at working levels about ethical dilemmas to ground ethical considerations and solutions to the day-to-day circumstances of employees and managers. Stigmas associated with talking about ethics need to be removed. Learning should involve consideration of cases studies. Employees need to work through case studies that are relevant to their particular operational circumstances.

Staffing

 

Key personal qualities and competencies sought in a values and ethics advisor include: sound judgement, organization awareness, discretion, investigative capacity, and excellent interpersonal skills.

Staffing processes should incorporate assessment of the values and ethics of recruits. Orientation training for recent hires must also include values and ethics instruction.

Staff performance evaluation

As part of management training a 360-feedback exercise is required. This includes a generic assessment of values and ethics.

There is room for further defining performance requirements. Performance can be assessed against a checklist of suggested managerial actions for promoting a good values and ethics climate in the department.

Plans

A multi-year plan for the program will be developed. Consultations will occur within the department with respect to risks and the longer-term values and ethics support needed by all employees (managers, rotational and non-rotational staff, and staff locally engaged in missions abroad).

A multi-year values and ethics roadmap is needed covering all investments and interventions for embedding values and ethics in the organization.

Organization

See organization structures above.

Operational managers believe that to avoid isolation the values and ethics program must work at enhancing its visibility and also become an integral element of management processes.

Another organization factor is ensuring the Division has on staff a rotational officer (e.g., Management Consular Officer) familiar with operating conditions abroad.

At the branch level the model employed by Employment Equity could be considered. Branch representatives who were designated as champions of Employment Equity sat on a departmental champions committee. Each champion served as an advocate for Employment Equity within their organization and reported directly to the ADM about surveys and assessments of progress.

Committees/ Working groups

Informal communications within the organization seems to function adequately. The Division participates in the HR Advisory Committee.

As volumes of cases and requests for advice increase more formal coordination mechanisms may be required.

Risk management

Regular discussions have occurred with the audit directorate as well as with the geographic bureaus regarding risk.

In consultation with the audit directorate an inventory of ethical risks is required to build into integrated risk management efforts. The ethical risks of the department should be identified and understood through many dialogue sessions and other evaluative approaches with staff.

The department should continue to strive for the right balance between control/compliance and values driven approaches.

Performance measurement and reporting

The department carried out an all staff survey, which included questions with respect to workplace satisfaction and harassment.

Any gaps from the previous survey could be assessed through the application of an additional survey. However, this survey should only be implemented once the program becomes more established, and once appropriate performance measures have been developed and tested.

Branches should receive a yearly presentation (not more than 3 pages please!!!) from the Division about what worked well and what did not work well to aid in their efforts to enhance values and ethics practices.

Recourse mechanisms

Standard disclosure mechanisms are in place for internal disclosure (e.g., toll-free line, e-mail and fax). Heads of Mission have developed informal peer groups in geographic areas to provide a source of advice and discussions of common concern.

The results of investigations (harassment and internal disclosure) need to be made known (within the boundaries of confidentiality). As a rule employees are hesitant to take the first step of unloading their concerns on an advisor. Awareness building among staff can contribute to creating an enhanced sense of safety and confidentiality regarding disclosure.

4.0 Health Canada (HC)

Figure 5: Health Canada (HC) Governance Model for Values and Ethics
Health Canada (HC) Governance Model for Values and Ethics. Text version below:
Figure 5 - Text version

The Health Canada governance model is led by the DM/Associate Deputy Minister who directly oversees Branches and the DG of Audit and Accountability Bureau. The DM/Associate's role is one of exemplary behaviour, participation in events and encouragement of subordinates.

The Branches are responsible for leadership and participation in values and ethics focussed activities. They are able to access support of the Centre for Workplace Ethics.

The DG Audit and Accountability Bureau oversees the Directors of Audit Operations, Special Investigations and the OAG Liaison. The DG also oversees the Executive Director who is responsible for three separate functions: the Centre for Workplace Ethics, for Ombudsman and Informal Conflict Resolution, and the Internal Disclosure Office.

The Executive Director reports to the DM/Associate Deputy Minister on Disclosure and Ombudsman matters.

Centre for Workplace Ethics

Key Outcomes (Vision): To help foster an ethically sound and vibrant culture that best embodies Health Canada and Public Service values and ethics and, to promote ethical behaviour.

Mission (excerpts): To achieve our vision by: awareness and learning; open and ongoing dialogue; integration in activities and processes; the assessment of ethical strengths and weaknesses; and implementation of reforms.

Primary Activities: Awareness and learning activities; development of tools to foster decisions; and outreach and partnership with respect to dialogue sessions, learning integration, internal communications and external linkages.

The model identifies linkages inside the organization including:

  • Linkages with Executive Committees including Departmental Executive Committee
  • Human Resources for Conflict of Interest, post-employment, and harassment
  • Learning Centres
  • Regions with: Regional Director General Offices, learning centres and participation in retreats.

The model also identifies linkages outside the organization with:

  • Public health Agency of Canada
  • Co-Founder of Inter-Departmental Ethics Committee
  • Professional Organizations
  • Conference Board
  • PSHRMAC Academic

For the purpose of an MOU with PHAC to provide ombudsperson, Ethics and ICMS services.

Governance model

"Integrating values and ethics in the organization culture"

Evolution of ethics model

The Centre for Workplace Ethics (CWE), established in 2001, opted for a values-based ethics program, leaving most of the compliance responsibilities with previously designated functional areas. A values-based program was also thought to be an appropriate fit with expectations of doctors, nurses, scientists, and other professionals who were already governed by professional values and codes of ethics and who comprise almost 40% of the workforce at Health Canada. During 2001-2002, CWE launched an extensive dialogue with over 700 people at all levels of the organization to establish values uniquely representative of the aspirations of Health Canada employees. Feedback from the dialogue confirmed the appropriateness of a values-based approach to engage and support employees in their personal and collective commitment to integrity. The dialogue also yielded a great deal of additional data from which the Centre developed an action plan to increase awareness and understanding of its core values in order to integrate ethical values and considerations into workplace activities.

Since 2003 CWE has been enacting its action plan. The plan addresses the following four main areas:

  • Communicating HC's core values and the results of the dialogue;
  • Integrating HC's core values through measures such as learning events, advisory services, profiling best practices and partnership activities to explore integration possibilities;
  • Assessing progress and measuring progress, by monitoring and analyzing trends, integrating HCs core values in the audit process, research on best practices, and the development of a Deputy Minister's Award for Values and Ethics;
  • Continuing the dialogue, by further analyzing the data from the dialogue already conducted, and also conduct more focussed dialogue session to address specific issues of interest and concern.

CWE has developed a variety of learning activities: generic sessions, generic sessions with customized components, and fully customized sessions (Ethics 101, Ethical Distress, Ethical Leadership, Approaching Ethics as a Management Team, Ethical Decision Making) as well customized sessions (orientation,team building and renewal, sessions for scientists, etc.). The Centre has also developed a number of case studies relevant to HC's activities.   CWE has also begun measuring its performance in its learning activities against a number of desired outcomes. A more comprehensive listing of activities and tools may be found in the table at the end of this profile.

In the future the Centre intends to further integrate ethics into policy and operations and begin to explore the impact of its program on behaviour. CWE's current measures of success include participation rates in learning activities, qualitative and quantitative feedback on learning activities, and the number of requests for packaged and customized services, which emanate from all sectors and regions of Health Canada.

Outcomes of Health Canada's ethics program

  • Immediate - Greater individual and collective openness to questioning, dialogue and debate on questions of ethics and values, thereby helping HC staff to reflect more fully on all ethical aspects of their work and exercise enhanced personal ethical judgement.
  • Intermediate – A fuller integration of HC and Public Service values and ethics in departmental management, structures, processes and informal practices leading to shared leadership and a more robust ethical culture overall (doing good) with reduced ethical risks (reducing harm).
  • Ultimate – 1) Improved quality of service delivery to Canadians as a result of the optimal balance of HC and Public Service values integrated into departmental culture and activities; and 2) minimized risk of ethical failures.

Organization structure of the centre for workplace ethics (2001-06)

The organization structure is outlined in the chart below. CWE is housed within the Audit and Accountability Bureau (AAB). By the time this report is published CWE will be housed within a new branch, Public Affairs, Consultation, and Regions Branch. The Centre is headed by a Director with a total of four staff, all of whom have expertise in specific organizational areas as well as ethics. The Centre utilizes a portfolio approach to serving needs of clients. Different staff members focus on the scientific community, the nursing community, and the broader organizational community. They frequently collaborate in the development and delivery of specific learning activities and tools. Each member is also responsible for specific regions. The total budget for CWE is $650,000 comprising $370,000 for salaryFootnote 3 and $280,000 for O&M.

Figure 6: Organization structure of the centre for workplace ethics (2001-06)
Organization structure of the centre for workplace ethics (2001-06). Text version below:
Figure 6 - Text version

The Health Canada Centre for Workplace Ethics organizational structure includes an Executive Director and 4 staff (3 AS-7s or AS-6s and 1 AS-1) who have adopted a portfolio approach to clients.

How the model works

With the introduction of the Internal Disclosure Policy in 2001, a senior officer was appointed who reports on disclosure matters directly to the Deputy Minister. In 2003, with the creation of the Office of the Ombudsman, matters disclosed to this office also reported to the Deputy Minister. The Disclosure Office has a few cases a year, the Ombudsman Office over 500 cases annually.  The Director in the AAB maintains an internal network in the department to share information, trends and generally ensure the process and case management is well coordinated. Meetings are held three times a year and include representatives from legal services, communications, Access to Information, union representatives, regions, audit, HR and security.

CWE follows a self-described "entrepreneurship" model. The relevance and reputation of the centre depends on its ability to develop relationships with clients and stakeholders and demonstrate a value added service. As a consequence all staff members have competencies in interpersonal, research, and analytical skills, public presentations, problem solving, collaboration, developing and sustaining partnerships, and practical and theoretical ethics. Staff frequently travel to regions.

The HC model has been one of stability, developing people from within, investing in expertise in ethics when necessary (all staff members have post graduate expertise in ethics or have acquired expertise on the job) and lending help and support to other departments.

Program overview:  Practices for embedding V&E in culture of organization

Structure or Process Current Activities Factors for Success

Leadership

DMs Award of Excellence for Values and Ethics. 

Interactive half-day sessions with management teams on developing values and ethics strategies.

More general learning activities, which encourage shared or distributed leadership and promotion of ethical judgement.

DEC has recommended that each region and branch develop plans to increased learning.

 

Highlight importance of V&E and top management support.

Moral leaders must be and be seen to be moral managers capable of operationalizing ethics and modelling appropriate behaviour. 

Create an atmosphere in management committees where values and ethics discussion is welcome.

V&E integrated into performance measurement of EXs.

Leaders must renew V&E regularly through the sponsorship of active dialogue, as an ongoing aspect of the management agenda.

Policies and guidelines

Provides guidance and expertise within the department and to other departments with respect to the application of the code.

Developing code of conduct (being conducted by HR with input by the CWE).

Working with regulators to develop specialized charter of values.

V&E has an internal focus on mandatory and discretionary behaviour and an external focus on contributing to the public good.

Communications

Booklets on core values, ethical decision-making, ethical distress, a values charter exercise, ethical assessment tools, posters, brochures and bookmarkers, ombudsman toll-free service, among other resources. 

Employees need to see proof that the system is working:  role models are especially effective.

Focus group suggested a "normalized" process of dialogue or discussion with staff, rather than the Centre waiting to be invited to participate. Good management suggests that CWE engage, at regular intervals, in dialogue with organizational units about risk and opportunities to build ethical culture.

Learning

Designed and delivered ethics workshops and orientation sessions, including customized learning material for teams:  Everyday Ethics, Ethics 101, Ethical Distress, Ethical Decision Making, Ethical Leadership, and Approaching Ethics as a Management Team.  

Other learning products especially for executives include supporting ethical conversations, team building, coaching circles, reducing silos.

Ethics modules have been integrated into orientation, and management-training programs.

More than 3,445 participants have been engaged in ethics learning activities, excluding short information sessions. 

CWE is customizing existing awareness and learning products for nurses, scientists, management, HR, Financial, the regulatory community, etc.

The Department Executive Committee has recommended that each region and branch develop plans to increased learning.

Workshop participants highly recommend mandatory training, especially for managers.

Managers perceived sessions as very useful in exchanging ideas among peers.

Any course offered by the Canada School or within the department should contain a values and ethics component. Values and ethics should not only be the subject of stand-alone courses.

Material requires continuous updating. 

Staffing

Advisory services on staffing values

 

The department has a voluntary process of exit interviews for departing employees that is not uniformly implemented. Focus group participants believed this procedure could be normalized and results made accessible.

Staff performance evaluation

Beginning to offer concrete recommendations on ways of better integrating concern for fundamental values into regular departmental processes (e.g., in staffing and performance competencies).

Ex.'s have three indicators for the evaluation of values and ethics.

The department should ensure consistency in the evaluation of EX's apropos three V&E indicators.

Tools

Quizzes, questionnaires and exercises have been developed as awareness tools. A bank of case studies, a website, and other ethics resources materials have been developed.

 

Plans

The Office of Integrated Management in Health Canada is focussing on the development of more integrated and consistent approaches to business planning.

The planning of business lines should incorporate performance measures (e.g., complaints), the identification of potential ethical risks, and a general assessment of the values and ethics "health" of the organization.

Environmental scanning should integrate considerations of ethical risks that are founded on detailed risk management frameworks and processes at branch and directorate levels. 

Organization

See chart and description above.

Matters of advice and recourse should be kept separate from learning, policy and ethical engagement.

Another three or four officers would allow more tools to be developed as well as ensuring regular dialogue occurs with organizational subunits.

CWE should serve as a "point of focus" for advice, tools, and learning.

Committees/ Working groups

 

Establishment of networks permits 'leveraging' of efforts to ensure progression of the values and ethics program.

Risk management

Others within the department are focussed in this area, including on compliance matters. The audit group is focussed on matters of controls, finance and risk. They are reported to consult with CWE when developing risk assessment profiles.

Risk management frameworks should incorporate inventories of potential risks. Level and type of risk should be weighed across every organization in the department.

Performance measurement and reporting

HC reported against the Management Accountability Framework requirements for Values and Ethics. CWE has developed a logic model, performance indicators, and survey tools. 

CWE piloted pulse-taking tools, short confidential surveys, as a starting point for team dialogue. Staff assess their work environment against value ideals and key ethical characteristics of the workplace.

There is a need to have tools to measure the "ethical climate", but it should not be a repetition of the PS employees' survey. If so, fatigue and lack of interest will set in.

5.0 Public Works and Government Services Canada (PWGSC)

Figure 7: PWGCS Governance Model for Values and Ethics
PWGCS Governance Model for Values and Ethics. Text version below:
Figure 7 - Text version

PWGSC has a consolidated governance model with the DM at the head. Below the DM are the Chief Risk Officer and Senior Officer as well as the Branch Heads/Regional Directors General/Agency Heads. The DM also participates in the Risk and Ethics Committee.

The Chief Risk Officer and Senior Officer oversee the Ethics Directorate which includes: a Director, 4 staff, 14 ethics officers are located in regions and branches to assist PWGSC in implementing the 10 Point Integrity Plan. The Directorate participates in and supports the Ethics Leadership Team. Its areas of interest include the public service Values and Ethics Code and the development and interpretation of PWGSC's policy on Gifts and Hospitality.

The Chief Risk Officer and Senior Officer also oversee other Managers and Directors in matters of internal disclosure, fairness monitoring, and risk management.

The Branch Heads/Regional Directors General and Agency Heads are supported by the Ethics Directorate (advice, support and liaison) and has oversight of the Ethics Leadership Team. The ADM Corporate Services HR and Communications has responsibility for: conflict of interest (Ch.2 of the Code); post-employment (Ch. 3); avenues of resolution (Ch. 4); informal conflict management; harassment; political activities; employee and organizational assistance; and human rights.

The Ethics Leadership Team is responsible for building and maintaining capacity and providing leadership and support in the integration process.

Ethics Program

Mission: Provide the focus, framework and processes to guide, assess and continuously improve the ethical conduct of PWGSC and its employees.

(Vision) Key Goals: a) Regain and maintain the confidence and trust of Canadians, PWGSC employees, governments, and industry; and b) Ensure that all PWGSC's employees (and stakeholders) are equipped to perform their duties in accordance with the highest ethical standards.

Scope: Requirements of Code and statement of values.

Activities/Elements: 1) Leadership; 2) PWGSC Statement of Values; 3) internal communications; 4) external communications; 5) alignment of governance structure and processes; 6) infrastructure for assistance and guidance; 7) standards of conduct for external stakeholders doing business with PWGSC; and 8) education, development and training.

The model identifies linkages inside the organization including:

  • HR
    • Referral to HR of questions/inquiries in their centre of responsibility (e.g., Conflicts of Interest)
    • Training programs
  • Risk management – integration of.

The model also identifies linkages outside the organization with:

  • CSPS
  • Academic Institutions
  • Associations

For the purpose of training, knowledge and best practices.

Governance model

"Integrating values and ethics in the organization culture"

Evolution of values and ethics model

PWGSC's top priority is to create a department that is widely acknowledged as a leading ethical organization. PWGSC Ethics Program is values-based which assumes employees are already committed to ethical behaviour. The program was established to provide the focus, framework and processes to guide, assess and continuously improve the ethical conduct of PWGSC and its employees. The program was first made up of five strategies:  focus on leadership commitment; engaging in ethical dialogue; aiding employees in decision-making; providing ethical advice; and counselling and supporting the consensus of what constitutes good ethical action.

The program formally began in 1997 when a senior management champion of the ethics initiative was nominated and subsequently appointed in 1999 as the Senior Departmental Ethics Counsellor. Also in 1999 the Ethics Development Office (EDO) was established to support the goals of the Ethics Program. The EDO was a small office designed to assist employees, sectors and branches by providing information so they could incorporate ethical considerations into their approaches, regimes, plans and strategies. To establish the Ethics Program and secure buy-in from senior management within the department, an Ethics Leadership Team (ELT) was established comprised of executives from the different Branches/Regions and Agencies of PWGSC. This provided a forum to discuss how values and ethics impact their work.

In 2003 the department established and communicated to employees a Ten-Point Integrity Plan as detailed below. Although the EDO was responsible for providing coordination and assistance in implementing the plan Branches, Regions and Agencies in PWGSC are accountable for the quality of the ethical climate in their organizations by implementing the plan as follows:

  • Clarify management accountability by realigning the organization.
  • Establish a robust ethics infrastructure by having Ethics Officers in all Branches, Regions and Agencies.
  • Establish links with other levels of government to share knowledge on ethical issues.
  • Communicate the Ethics Framework.
  • Strengthen and promote the PWGSC
  • Statement of Values and provide guidance in its application.
  • Publish guidelines for assessing and managing ethical risks.
  • Include accountability for integrity as a factor for performance pay.
  • Provide ethics orientation, training and ongoing support in every Branch, Region and Agency. (A target was set of 70% of employees in 7,700 positions-at-ethical-risk and all managers to receive the basic Ethics training by the end of the 2005/06 fiscal year. Total staff in the department amount to 13,000)
  • Encourage discussions on ethical issues within the department.
  • Inform clients, service providers and the general public of measures taken to ensure PWGSC's integrity.

Until recently, the Director General of Audit and Ethics Branch was the designated Senior Departmental Ethics Counsellor reporting to the Deputy Minister. In October 2005 the Office of the Chief Risk Officer (OCRO) was designated this responsibility as well as for the ED. Within the last year, the Ethics Development Office was renamed the Ethics Directorate (ED) with continuing responsibility for the Ethics Program supporting the Ten-Point Integrity Plan. In addition, the core ED staff was expanded to include 14 Ethics Officers located in Branches, Regions and Agencies to provide advisory services and awareness building.

Goals (outcomes) of the ethics directorate (program)

  • Regain and maintain the confidence, and trust of Canadians, PWGSC employees, Governments, and industry
  • Ensure that all PWGSC's employees (and stakeholders) are equipped to perform their duties in accordance with the highest ethical standards.

Organization structure of the ethics directorate

The current organization structure is outlined in the chart below. The Director of the Ethics Directorate reports to the Chief Risk Officer. The Director maintains a core staff of 3 AS-7s responsible for policy and communications, training, and case management. Fourteen Ethics Officers (AS-6) report, within a matrix management structure, to the three AS-7s in ED. The Director funds their salaries and selected values and ethics projects undertaken for the department.

The reporting relationship between the AS-7s and the Ethics Officers is for administrative purposes (evaluation and workload) and guidance. To ensure a consistency in approaches to advice giving and program implementation, ethics officers meet together regularly and are also required to seek the advice of the AS-7s about cases. Ethics officers develop working relationships with each AS-7 on different issues, cases or projects depending on the subject matter expertise and responsibility of the AS-7.

The ethics officers work within PWGSC as a consolidated organization. They report substantively and are funded by the ED, which sets their responsibilities and scope of activities. However, they are located within Branches, Regions and Agencies as service providers, providing functional advice, guidance, assistance in the development and implementation of ethics action plans, and awareness building support to the Branch/Region/Agency head. The focus of the direction applied by the ED is ensuring the Ethics Officers are well integrated in the activities of the branch, within the scope of their responsibilities and to ensure a consistency in the implementation of the values and ethics program.

The responsibilities of the officers and the core staff are described below ("How the Model Works"). The staffing level for the Directorate was based on a variety of considerations including but not limited to: 

  • A decision to make the Ethics Officers full time based on the expected workload including training requirements (mandatory target of 70% of employees at ethical-risk in 2005/06 increasing to 100% in 2006/07), and responsibilities for such activities as ethical inquiries, developing action plans, providing advice, developing policy, and participating in meetings and other awareness building activities. The 'capacities' defined for Ethics Officers include: putting in place diverse policies and initiatives; working in teams; working under pressure; knowledge of training; and ability to present and communicate effectively. Knowledge and experience is required in areas such as: departmental mandate; integrating ethics in the work environment; project management; analyzing inquiries; advice on matters relating to ethics; and training and awareness building with respect to values and ethics.
  • The need for core staff expertise in primary areas of Directorate responsibility for policy, communications, training and case management. A primary reason for this is to ensure consistency and quality assurance regarding the implementation of values and ethics interventions (e.g., training). The core staff workload covers cases and the handling of ethical questions, which are projected to rise as mandatory training builds awareness and interest.
  • At the regional level there are a number of programs with dedicated staff providing services to employees and managers including EOAP, ICMS, Ethics and Harassment. EOAP, Ethics and Harassment are decentralized with staff located in regions, while ICMS regularly sends staff out to the regions. Each organization indicated that their unique requirements, different manner of interaction with clients, confidentiality concerns and other considerations justified separate staff in regions. PWGSC managers recognize that significant awareness building efforts are needed to ensure employees understand the different roles and contributions of each type of officer.

The Budget of the Directorate is $2 million involving $1.65 million in salaries for 19 FTEs and $350,000 O&M. Branches fund training costs. O&M has been used for travel costs for meetings, training costs for staff, translation, and temporary help. Training of ED staff is a crucial to ensuring they provide sound and consistent service.

How the model of the department works

The Department has developed a detailed terms of reference or framework which sets out Ethics Program goals, structure and related responsibilities. The table below provides a summary description of the framework of responsibilities:

How the model of the department works
Framework element Summary of roles and responsibilities

Chief risk officer

Senior Officer - Application of PS code; policies and directives on acceptance of Gift and Hospitality and Lobbyists; factual investigation of Conflict of Interest, but final determination rests with ADM-CSHRCB; and Internal Disclosure of wrongdoing.

Senior Departmental Ethics Counsellor – Ethics program authority; ethics policy, guidelines and procedures; implementation of Ethics Program; counsellor and advisor, including to Executive Committee (EC) members and the EX community; periodic review and analysis of business plans and departmental policies and other significant initiatives for the inclusion of ethics requirements; and monitoring the effectiveness of the ethics program.

Risk and ethics committee

Approve policies on ethics; resolve program issues; approve workplan and budget for Ethics Program; and ensure overall effectiveness for the Ethics Program.

Branch and agency heads and Regional Directors General (RDG's)

Developing an ethical culture supportive of the highest ethical standards; education/training; developing safe mechanisms for employees to raise ethical concerns; monitoring the Ethics program; and promulgating the PWGSC Statement of Values (e.g., through aligning programs, structures and processes).

ADM – Corporate Services, Human Resources and Communications (CSHRCB)

Ensuring all HR programs are developed and delivered in accordance with the PWGSC Ethics Program; implementing programs such as harassment, prevention, resolution and Conflict of Interest; learning activities and tools; integrating the ethics program elements; reporting on ethics learning; conducting evaluations on the effectiveness of learning; and coordinating the delivery of ethics learning in the National Capital Area.

Management and supervisors

Supporting/adhering to ethical standards and ensuring that the department's values form an integral part of their working environment; providing opportunities for a dialogue on ethics; meeting at least one hour per year with subordinates on a formal basis to provide an opportunity to raise ethical concerns or risks; promoting an ethical climate; and providing advice, information and support to employees.

Employees at all levels

Familiarization with PWGSCs Statement of Values and Ethics Program; supporting/adhering to ethical standards and values; reporting to supervisor any knowledge or awareness of unethical actions; and participating in learning opportunities.

Director, ethics directorate

Awareness; plans on ethics related policies and procedures; research; assisting managers and staff; participating in developing training; supporting Branches, Agencies and Regions; maintaining confidential communications; ethics counselling and advice; investigating procedures; ethics materials in communications; centre of expertise through liaison with ethics experts; lessons learned; monitoring the status of the program; consultation, coordination and support to the Ethics Leadership Team (ELT); and evaluating the performance of Ethics Officers.

Ethics officers

Supporting their ADMs/RDGs/CEOs in fulfilling their mandate, within their respective organizations, as it relates to the Ethics Program in providing services such as:  a) assisting Branch management and staff in resolving ethical issues and ethical decisions (information, advice, guidance, coaching and follow-up); b) providing management support (e.g., ethics training, identifying ethical issues and trends, reporting on the integration process, promoting ethical practices, participating in management meetings, and conducting dialogue sessions; and c)  acting as liaison officer (e.g., between the Ethics Directorate and the Ethics Leadership Team member and with other external and internal stakeholders).

Ethics Leadership Team (ELT)

The Team is composed of executives in branches, regions and agencies responsible for assisting their ADMs/RDGs/CEOs in:  a) building and maintaining capacity (e.g., by acting as a sounding board for the Ethics Directorate, sharing of initiatives in their business lines, working in close collaboration with their Ethics Officer, and attending regular ELT meetings); b) providing leadership and support in the integration process (e.g., by integrating the program in their business lines, promoting the program; liaising with the Ethics Officer, identifying risk areas, and advise on performance and measurement indicators.)

There are eight defined elements of the ethics program as follows:

  1. Leadership commitment – managers at all levels exercise sound ethical leadership, starting with senior management and cascading downward
  2. PWGSC Statement of Values – a living document setting the ground rules for behaviour, interaction and decision-making
  3. Communications – build awareness, maintain momentum, secure feedback, communicate success
  4. Alignment of governance structure and process – Ensure policies, plans, procedures, practices of all parts of the department are consistent with the Statement of Ethical Values
  5. Education, development, and training – promote dialogue; awareness and knowledge of ethical issues; commitment to ethical practices and behaviours; and familiarize people with the PWGSC Ethics Program
  6. Infrastructure for assistance and guidance – Enhance ethics advisory services by establishing ethics officers in all Branches; develop appropriate tools; and establishment of a help-line.
  7. Communications with suppliers and external stakeholders – Communications tool for suppliers; consultation and dialogue with external stakeholders; and publication and distribution of the communications tool.
  8. External Communications – Communicate stories; develop an ethics website; communicate with industry, other government departments and Canadians; and establish seminars with industry.

The day-to-day work of the program relies on the relationship between the Directorate and Ethics Officers. Currently the focus of their activities is primarily in learning activities, case management, revision of the PWGSC Statement of Values, awareness building of the program, policy development in Gifts and Hospitality, staffing actions and coaching of new employees. A logic model was developed for the Ten Point Integrity Plan, which sets out the activities, outputs and anticipated outcomes. This will serve as the basis for planning and resource decisions.

In establishing the Ethics Officers positions, the Directorate relied on the Ethics Leadership Team to achieve buy-in and agreement on the officers' roles and responsibilities and for guidance on the evolution of the ethics program. The Ethics Leaders continue to provide a key entry point for the Ethics Officer in promoting the program and seeking to generally integrate ethical approaches in operations. For example, Ethics Leaders were asked to ensure a three-year action plan was developed for integrating ethics, which focussed on measures such as performance pay and achievement of training targets. Another instance of cooperation between the Directorate and the leaders has been in the identification of higher risk employee groups who should receive the first round of mandatory ethics training. 

The Directorate also has regular day-to-day interactions with staff in the HR Branch, particularly with respect to case management (e.g., Conflict of Interest). Managers from all values and ethics areas depicted in the graphic at the beginning of this profile have adhoc meetings to discuss common issues and regularly communicate on day-to-day case management matters. 

The Directorate developed memorandum of understanding to formalize its operating relationships with HR groups. The goal was to develop protocols for interaction and sharing of responsibilities, as well as a databank of cases that could provide reference material for:  a) ensuring consistency in handling requests; b) developing case studies for use in training and as a basis for developing operational guidelines, policies and/or standards.

Overview:  Practices for integrating V&E in organization culture

Structure or process Current activities Factors for success

Leadership

Announcements from the Deputy Minister, ADM round tables, decisions on investment in additional resources, organization changes, among other leadership efforts.

ADMs are accountable for the ethical climate of their organizations assisted by ethics professionals, ethics leaders and other avenues of support. Ultimately, this accountability will be assessed through performance measures. A fine balance must be struck between making proscriptions of what must be done by ADMs versus ensuring flexibility to implement.

The stability of the Ethics Program is dependent on a clear and communicated vision and leadership support. A key hurdle to overcome is the perception that all departmental employees are considered blamed for recent government ethical lapses. A genuine interest among employees in discussing values and ethics needs to be encouraged. Positive messaging by leaders about the potential contribution of an ethics program is vital so as to not make employees feel that they are considered unethical due to an increased attention to the program.

Another key leadership requirement is to "walk the talk" in demonstrating strong ethical behaviour.

Policies and guidelines

Apply the Values and Ethics Code for the Public Service to the departmental environment. Revision of the PWGSC Statement of Values.

In the workplan for 2006/07 the ED will produce a strategy to review existing policies to ensure their alignment with the outcome of the ethics program and the statement of values.

A framework and guidelines for developing a supportable values and ethics program is crucial. In addition, the PS Code needs to be applied and publicized in clear and simple language.

 

Communications

Continued rollout of the Integrity Plan Communications Strategy, including an awareness campaign, website strategy (internal and external websites), regional input for articles, and support to Acquisitions for a code of conduct. Posters, website, kiosks and other materials have been developed, as well as reporting tools.  

Above all, the communications of the Ethics Program needs to be constantly refreshed. The messaging needs to continue to attract the interest of employees. Positive messaging through success stories is important.

A vital purpose of communications is building awareness among employees to know where to go within the organization to obtain advice or redress. This requires clear and simple language describing the role of the program, partner programs (e.g., harassment), ethics advisors, leaders and employees. The current website provides information, including identifying the multiple access points by employees. In addition to standard communications products (posters, kiosks, websites, e-mails, pamphlets), learning events also build awareness of the role and services of the program, as well as to clarify the role of the ethics program relative to other programs. In addition to the official reminder of employee obligations under the Values and Ethics codes other communications are developed to enhance awareness. Managers and Ethics leaders must play an important role in building awareness and be encouraged with the right tools and instructions. 

Learning

Learning is a key element of the program. A mandatory target was set of 70% of employees in positions-at-ethical-risk and managers to receive the basic Ethics training by the end of the 2005/06 fiscal year. This will increase to 100% by 2006/07. Ethics Officers and Directorate Staff have made presentations to various learning events and at management and staff retreats. Ethics Officers are required to develop their own learning plan to support their responsibilities.

The department made the decision to mandate a target for training to be funded from Branch/ Region/ Agency budgets. This was considered a vital element of enhancing awareness. During training sessions reservations about the program are dispelled and buy-in occurs.

Dialogue about the direction of the program and about ethical dilemmas is vital. This must occur at the working level and with senior management. Dialogue should consider ethical dilemmas, clashes of values, as well as the relationship between PS values and ethics and professional codes/standards (e.g., engineers).

Presentations and other awareness building are vital to developing an appreciation of the developing role of the ethics program. These can occur at venues such as managers' conferences, EX-conferences and retreats, sector staff meetings, etc.

Staffing

Competitions to stabilize ethics positions are being completed.

Hiring of departmental employees makes reference to values and ethics competencies.

Positions in the Directorate are staffed with AS positions compared to the use of PEs within the HR Branch. The two types of classification vary in their educational and training requirements. Labour relations can be an element of PE training, which may afford some wider perspective on organization issues, including conflict management and counselling.

Although competencies for values and ethics may be identified for hiring purposes, the challenge is in fully assessing the applicant's actual achievement of defined competencies.

Staff performance evaluation

As part of the Ten Point Integrity Plan the department set as goals the integration of values and ethics within performance evaluation and pay at risk decisions.

EX performance accords include reference to values and ethics. 

Indicators can be developed regarding the quality of the ethical climate (e.g., harassment complaints, turnover, grievances, conflict, stress levels, absenteeism, etc). The PS survey also provides some disaggregated information of use in assessing ethical climate. Yet, these do not tell the full story. A more comprehensive performance architecture needs to be developed that is transparent about the guidelines, expectations and measures in place. In the absence of agreed to and defined performance indicators it may be necessary to take a more proscriptive approach to ensuring performance in integrating values and ethics is achieved. This can be done through reference to plans or checklists of initiatives or actions that need to be undertaken. A suggested list of these actions can be developed through the work of the Directorate, Ethics Leaders, Ethics Officer, senior management, and committees.

Tools

A sheet describing the needed steps for ethical decision-making has been prepared and disseminated. Other tools used are:  website and the 1-800 lines.

Decision-making tools are considered very useful, including even checklists to provide an "ethics filter" for decisions. Case studies are also considered useful in demonstrating how good ethics decisions can be made. It is then a matter of training and practice to ensure  decision-making approaches are intuitively applied in day-to-day work.

Plans

The Ten Point Integrity Plan will be operationalized through the action planning of Branches, Regions and Agencies. The Directorate will continue to plan its activities for next year and beyond. The Directorate is developing a long-term sustainability plan for values and ethics, involving both strategy and tactical plans.

Ethics considerations need to be integrated within Business Planning processes. As part of this, ethical dilemmas, risks and problem areas need to be identified and the right structural changes or interventions identified and resourced. At a departmental level, a multi-year roadmap of the ethics program is needed to set the longer-term direction and expected achievements.

Organization

See organization structure and description above. 

 

Buy-in to the concept of ethics officers functioning in each branch, region and agency requires a concerted consultative role by the Ethics Leaders or champions. Ethics Leaders serve a vital role in large organizations in communicating initiatives to management and in ensuring integrity action plans are developed. 

The success of the program hinges on the ability of Ethics Officers to become well integrated in the working culture of the department. This will require leadership, good collaboration and good competencies. Interpersonal relationships are absolutely crucial. Ethics Officers must be seen as experts, coaches and advisors.

The Ethics Directorate seeks a visible role in working with colleagues on integrating ethics considerations in policy, planning, risk management and other day-to-day management procedures. 

Committees/ Working groups

Informal communications between organizational units seems to function adequately. The Directorate participates in the Risk and Ethics Committee for direction setting and other managerial purposes, and acts as a secretariat and key participant in the Ethics Leadership Team. The Ethics Leadership Team meets three times a year in person and in-between through conference calls. The Ethics Officers meet very week to discuss cases to ensure consistency and enrich the rationale behind advice.

Coordination meetings and regular day-to-day communications are important. Generally, working relationships need to be forged and defined through protocols, meetings and other similar measures.

Changes in the audit function and its heightened importance are suggesting that audit, and ethics and risk are more appropriately handled in two different committees.

Risk management

Regular discussions have occurred with the audit directorate regarding risk.

The ethics program must be an integral part of culture change initiatives in the department, such as those related to organizational wellness and risk management. Risk and ethics are closely related since one of the biggest 'reputational' risks to departments comes from ethical lapses. A key goal of the program is to incorporate values and ethics within the activities underway to fully integrate risk management within the working culture of the department. This will cover areas such as hiring, performance appraisal, risk management, policy review, communications and procurement, among others.

Performance measurement and reporting

See information above in Performance Evaluation. Human Resources professionals prepare statistical reports on all programs (e.g., harassment and COI) that are incorporated in the Bilan Social. A quarterly report is prepared on labour relations, ethics, and corporate security among other areas.

It is important to have a regular dashboard of statistical and survey-based trends to assess the 'pulse' of the department and its individual organizations. There are some confidentiality concerns that make it difficult to report on indicators, changes in caseloads and ethical climate by individual branches.

The phrase 'ethical climate can include a range of considerations and concerns. For example, organization "wellness" was described by some interviewees as including the state of values and ethics in an organization. It concerns matters relating to physical (health), work (conditions), culture (norms) and people (psychosocial).    There are formal methods for gauging wellness, such as the PS Survey, which has included a few questions on values and ethics. The department is also considering introducing the Business Health Culture Index, which is a feedback method providing detail on issues around stress and work climate. 

In addition to indicators, the early warning of ethical concerns can come from informal sources. Feedback from training sessions, and the frequency and type of advice sought of advisors can provide indications. Through effective and sensitive dialogue it may be possible to identify these instances and try more collegial methods of support before formal methods are undertaken. For example, one branch in the department has developed a "culture club" to talk about organization wellness issues. 

Recourse mechanisms

Disclosure and other mechanisms are in place managed by other organizations within the department. A 1-800 line and other forms of confidential communications are in place. Ethics Officers serve as one conduit of services and can refer inquiries to the appropriate departmental program.

Ethics officers need a broad understanding of all departmental programs to appropriately advise individuals making inquiries to their offices, including about referrals. There is a concern among other programs in the department about avoiding duplication in advice giving between the Ethics Program and other programs.

Interviews suggested that the encouragement of disclosure is hampered by concerns about confidentiality. Clients are routinely informed that officers cannot guarantee confidentiality because of ATIP. 

Interviews also indicated that the EX community feels more exposed because of their accountabilities. They may rely partially on the internal advice giving or disclosure mechanisms of their department, but would also seek outside advice with peers or professionals (e.g., lawyers).

6.0 Royal Canadian Mounted Police (RCMP)

Figure 9: RCMP Governance Model for Values and Ethics
RCMP Governance Model for Values and Ethics. Text version below:
Figure 9 - Text version

The RCMP Governance model is led by a Commissioner who oversees the Office of the Ethics Advisor and Other Areas within the RCMP – each with specific responsibilities related to values and ethics.

The Office of the Ethics Advisor oversees the Ethics and Integrity Office of the RCMP and participates – with the Commissioner – on committees.

The Other Ares within the RCMP and their areas of responsibility include:

  • Labour Relations - harassment;
  • Professional Standards - COI, political activity, gifts and hospitality, standards with respect to the RCMP act;
  • Alternate Dispute Resolution – informal conflict management system;
  • Public Affairs – gifts, hospitality; and,
  • Internal Affairs – RCMP act.

Ethics and Integrity Program

Mission: Promoting standards of ethical behaviour among employees of the RCMP: Live and promote the core values of the RCMP.

Scope: Code of Values and Ethics of the Public Service. Adherence to such standards will guide and direct policy development, training and accountability, and encourage behaviour that will foster a respectful workplace.

Key Outcomes (Vision): Together these elements will enhance and reinforce public trust in all levels of our organization – "…from sea to sea to sea".

Primary Activities: Leadership (commitment to ethical behaviour), learning at all levels ("golden thread of ethics" woven into all learning opportunities), developing an ethical network (network of formal and informal leaders across the organization), and measuring success (performance measures, baseline, and monitoring impacts).

The model identifies linkages inside the organization including:

  • Legal Services unit
  • Public Affairs and Communications Services
  • Other organizations with respect to the referral of disclosures in areas of their expertise (as shown above) and with respect to the RCMP Act (Professional Standards Unit and Internal Affairs)
  • Staff Relations – liaison with representatives

The model also identifies linkages outside the organization with:

  • Other Government departments
  • Other police forces

To ensure that MOUs contain a values and ethics clause to ensure RCMP values and ethics are observed.

Governance model

"Integrating values and ethics in the organization culture"

Evolution of values and ethics model

In the fall of 1995 the Commissioner of the Royal Canadian Mounted Police initiated the Shared Leadership initiative. This led to the establishment of the RCMP Mission, Vision and Values and the establishment in the fall of 1996 of the Office of the Ethics Advisor (hereinafter the "Office"). The Ethics Advisor was appointed to set into operation the mission, vision and values.

In 2001, the transition to a new incumbent as Ethics Advisor led to further development of the governance and organization structure of the Office of the Ethics Advisor. This included the establishment of the Ethics Council:  a cross-functional team at Headquarters to discuss issues relating to values and ethics. The Office was renamed Office of the Ethics and Integrity Advisor. The Ethics and Integrity Advisor is the Senior Official for the RCMP concerning the policy on Public Service Values and Ethics, and is also the Senior Officer for the policy on Internal Disclosure of Information Concerning Wrongdoing in the Workplace.

In 2004 the Office developed the Long Term Perspective to ensure continued momentum in the ongoing promotion of ethical behaviour amongst employees of the RCMP. The four pillars of the perspective were: 1) Leadership; 2) Learning (at all levels); 3) Network (an ethical network across the RCMP); and 4) Performance Measurement (measuring success).

In May 2005, the Long Term Perspective was revisited, renewed and revised to recognize evolving priorities. The original four pillars were confirmed as well as a commitment to build on the legacy of the past. For the future the Office will focus on:  prevention; early detection and intervention; understanding the root causes of unethical behaviour; and establishing strategies aimed at reducing risk, particularly for employees in high risk roles. This is a more strategic and advisory orientation to the Office as before when it acted as a type of "Ombudsperson" investigating complaints under its policy purview.

Outcomes of the values and ethics

Generally, the Office is committed to developing mechanisms to recognize both ethical and unethical behaviour, using an intelligence-led, integrated approach. This will be achieved by:

  • Fostering awareness for respect in the workplace;
  • Encouraging managers to be firm, but fair;
  • Motivating leaders to provide clear expectations to employees; and
  • Promoting pro-active feedback on performance.

Organization structure of the ethics and integrity division

Figure 10: Organization Structure of the RCMP Ethics & Integrity Division
Organization Structure of the RCMP Ethics & Integrity Division. Text version below:
Figure 10 - Text version

The Ethics and Integrity Division is led by an Ethics and Integrity Advisor (RX-14) who works in close collaboration with Legal Services and is supported: by 2 AS-2s (an office manager and an Ethics Advisor Admin.) supported by a Research Assistant (PSE). The Division is also staffed by an AM-05 – Associate Ethics Advisor who works in close collaboration with Public Affairs and Communications, and 2 Ethics Program Analysts at the AM-03 level.

The current organization structure is outlined in the chart at right.   The Ethics and Integrity Advisor reports directly to the Commissioner. 

The organization structure reflects approved responsibilities of the office for areas of activity, particularly internal disclosure. 

Functional responsibilities of staff members

Element/Positions Summary of roles and responsibilities

Ethics and integrity officer

Generally responsible for operationalizing the mission, vision and values of the RCMP. The Advisor:

  • Provides advice and guidance to the Commissioner including about specific cases;
  • sits as an advisor to the senior executive committee and also on other committees such as the malfeasance committee, pandemic planning committee and the legal risk management committee;
  • is co-champion of a harassment free workplace and bias free policing;
  • oversees the program and budget, which focuses on activities such as advice, education and training, policy research, reporting, among other activities.

Associate ethics advisor

Development and implementation of education initiatives; revisions to ethics policy; conducting presentations and assisting in training; sitting on committees; liaison with staff relations representatives; overseeing the research and activities of analysts.

Analysts

Project development in training and other initiatives; working with partners such as Public Affairs and Communications about a communications strategy and products; and provision of advice.

Research analyst

Research on best practices; and planned efforts to conduct an ethics environmental scan.

How the model works

The Office works collaboratively with different organizations in the RCMP in delivering its program and services. There are two levels to this collaboration:  1) Training and awareness building; and 2) Policy and advisory services. In the first level Office staff work closely with other organizations in the RCMP, such as Public Affairs and Communications to develop and implement communications, awareness building and training strategies. In the second area the office works with legal services regarding internal disclosure cases and related matters led by the Ethics and Integrity Officer. The Office is also consulted with respect to Conflict of Interest and harassment policies. With Professional Standards the office collaborates on policy and related matters to deal with issues such as community initiatives of officers, sponsorships (e.g., vehicle sponsorship policy), charity fund raising and the ethical decision-making around discretionary police powers. A key concern of the Office is how to apply policy, training and awareness building techniques to ensure RCMP members and staff "internalize" and then apply in their every-day affairs ethical decision-making techniques. 

Overview:  Practices for integrating V&E in organization culture

Structure or process Current activities Factors for success

Leadership

See description above of the role of the Ethics and Integrity Officer and the general description of Leadership.

Leadership is seen as a key factor in the achievement of a strong ethics culture by:  visibly holding people accountable; modelling good ethical behaviour; and promoting good ethical behaviour through openness in dialogue and setting a tone for dealing with inappropriate behaviour in the workplace.

Leaders need to encourage cultural change by voicing a strong rationale for change that highlights the role of the Ethics Advisor, and the importance of integrating values and ethics in day-to-day decision-making.

Policies and guidelines

The Office assists with policy development such as with Conflict of Interest. Provision of advice is an ongoing and important responsibility.

The Office is clear to point out that it does not serve an ombudsman role to investigate cases and render decisions. Its role is to provide advice. It may refer individuals to other recourse mechanisms within the RCMP. The ethics policy for the RCMP must draw a distinction between files that are handled or led by the Office relative to other ethical areas such as harassment.

Wrongdoing is subject to wide interpretation, which requires ongoing clarification by the Office. Matters of Gross Mismanagement are subject to the widest interpretation, as are Breaches in the Values and Ethics Code of the Public Service.

Communications

 

A positive "spin" is required regarding ethics. The department should communicate to the grassroots and demonstrate the relationship between values/ethics and the corporate culture (e.g., changes required to the corporate culture to bring in a values-based style of management and achieve open and transparent dialogue).

Learning

New and enhanced training courses are being developed and delivered, such as a professional ethics course delivered as part of training of cadets at the depot. Similar training would be provided to all employees and are also planned for senior management.

Training will build awareness, and further stimulate a "hunger" for values and ethics training. The concern is that mandatory training creates a reluctant attitude about participating and learning. Building awareness about the benefits and cost avoidance that training achieves will ensure active voluntary participation in training. Some organizations in the RCMP mandate training (e.g., Corporate Branch responsible for procurement).

Training is made relevant to the day-to-day concerns of members and staff through realistic case studies. These must be kept up-to-date using recent real cases.

Staffing

New recruits are rigorously screened for ethics. 

Competencies considered important to ethics advisors include:  understanding of ethics; knowledge and personal credibility in policing and ethics; communication skills (interpersonal and advice giving); knowledge of alternate dispute resolution; and presentation skills;

Staff performance evaluation

Disciplinary measures occur from violations of code of conduct. Officers are obligated to report any violations.

The Office is working to incorporate ethics as part of performance agreements.

A key challenge in performance evaluation is implementing performance measures for values and ethics. Competencies for ethics must be developed, and the required measurement and assessment tools and process.

Implementation:  Plans, tools and kits

Ethical deliberation model.

A goal is to ensure that each employee understands and gains practical experience in the application of the ethical deliberation model. By 'internalizing' the model through training case studies and practice, members and staff develop a better ability to logically defend their decisions.

Plans

 

An important part of planning is ethical environmental scanning in which the ethical context is described, as well as the full range of ethical risks and dilemmas facing members and staff.

The consideration of ethical risks and dilemmas as part of operational planning would assist in the integration of ethics in day-to-day affairs.

Organization

 

The role and responsibilities of the Advisor needs to be documented and promoted across the organization.

The Advisor should be someone who has tremendous credibility and integrity with both senior management and employees. He/she should report directly to the head of the organization.

A values and ethics connection needs to be forged between the Office and the regional level. This could include the development of a cadre of ethics advisors in regions to supporting the deputy commissioners. Aside from responsibilities for education, awareness building, communications and advice, the advisor would also assume an advisory role in other areas of Office interest such as bias free policing. Advisors would need to serve geographical areas such as the Pacific, NWR, Central and Atlantic.

There are some synergies possible between harassment coordinators in the regions, although the emphasis of their work is somewhat different. The harassment coordinator performs a more reactive role, while an ethics advisor takes a more proactive advisory role.

Committees/ Working groups

In addition to the committees in which the Ethics and Integrity Advisor participates, the Office is also involved in the Ethics Education Working Group. The group includes representatives from the regions and other police services, as well as an outside ethics expert.

Working Groups are important in obtaining outside advice in the development of policies and practical measures to integrate ethics within the working culture of the organization.

Risk management

 

A key component of developing an integrated approach to risk management is consideration of ethical risks at all levels of operation. The maxim "what is predictable is preventable" applies very well to this effort. Generally, the awareness needs to be fostered that greater application of ethical decision making approaches upfront reduces the "back-end" costs of handling ethical breaches.

Performance measurement and reporting

 

Seek an involvement with PSHRMAC with respect to measuring cultural change in ethics from a shorter-term perspective (What has been put in place) and a longer-term perspective (Whether you have achieved change).

7.0 Correctional Service of Canada (CSC)

Figure 11: Correctional Service of Canada (CSC) Governance Model for Values and Ethics
Correctional Service of Canada (CSC) Governance Model for Values and Ethics. Text version below:
Figure 11 - Text version

At the top of the CSC Governance Model is the Commissioner to whom the Assistant Commissioner HR Management and Assistance Commissioner Performance Assurance both report.

The Assistant Commissioner HR Management has responsibility for:

  • HR Management strategies – employee assistance
  • Learning and development – staff training, national training standards
  • Labour Relations – harassment, labour management relations

The Assistant Commissioner Performance Assurance supports and contributes to the Ethics and Values committee and has responsibility for:

  • Values and Ethics Branch – internal disclosure, conflict of interest, post-employment and informal conflict management system
  • Other Organizations – National Administrative Investigations, Audit, Evaluation

Ethics and Integrity Program

Role: Provide strategic direction for the Service's values and ethics program, including developing an integrated ethics strategy for the service.

Scope: Code of Values and Ethics of the Public Service, standards and Code of Discipline.

Primary Activities: Case and conflict management, advisory services, standards of conduct, training and awareness, ethical risk assessment, and leadership through champions and committees.

The model identifies linkages inside the organization including:

  • HR – Human Resource Management Strategies, Labour Relations and Learning and Development
  • On an as needed basis with legal, operations and others

The model also identifies linkages outside the organization with:

  • Inter-departmental meetings
  • ICMS Network

For the purpose of exchanges of expertise and best practices.

Governance model

"Integrating values and ethics in the organization culture"

Evolution of values and ethics model

A key priority of CSC announced in January 2006 is "strengthening management practices."  Two strategies supporting this are:  1) Improving internal communications; and 2) Strengthening the values and ethics framework. The latter strategy will be achieved through a:  a) national values and ethics program; and b) national Informal Conflict Management System. In December 2005 the creation of a new Values and Ethics Branch in the Correctional Service of Canada was announced which will focus on the implementation of the key elements of the CSC Ethics Strategy as follows:

  • Ethics Champion
  • Senior Officer of Values and Ethics/Internal Disclosure
  • Ethics Committee
  • Statement of Values and Ethics
  • Office of Internal Disclosure
  • Informal Conflict Management System
  • Standards of Professional Conduct and the Code of Discipline
  • Performance Assurance Website
  • Training and Awareness

CSC is also developing within the Values and Ethics Branch a capability to manage Conflict of Interest and Post-employment inquiries and advice. The Branch is also weighing organizational options for engaging the regions in necessary ethics dialogue, training and awareness building. Options range from the establishment of ethics committees or ethics advisors or champions or a combination thereof. There is a general appreciation for the need to have more understanding of the ethical dilemmas impacting on correctional operations.

Outcomes of the values and ethics

CSC is committed to a strengthened values and ethics program that responds to the nature of the correctional environment and the Values and Ethics Code for the Public Service and creates a stronger values-based workplace. This strategy is aimed at developing and implementing integrated plans that will build on existing programs to ensure that values and ethics is more fully incorporated into decision-making practices and is understood by employees at all levels within CSC. Plans in support of this strategy include:

  • Values and Ethics Unit: Integrate existing programs such as Internal Disclosure under one umbrella to provide strategic direction for a coordinated ethics program in CSC.
  • National Values and Ethics Program: Implement program and collect baseline data to establish targets for future improvement.
  • National Informal Conflict Management Systems (ICMS): Develop and implement the system.
  • Strengthened Independent Audit Function: Further enhance the independence and effectiveness of the Audit Committee by increasing the number of external members.

Organization structure of the values and ethics branch

The current organization structure is outlined in the chart below right.   This is a proposed organization structure currently under discussion, which reflects recent changes in responsibilities of the office particularly for internal disclosure and ICMS. The DG of Values and Ethics reports to the Assistant Commissioner of Performance Assurance, and on selected cases of internal disclosure and ICMS reports to the Commissioner.

Figure 12: Organization structure of the values and ethics branch
Organization structure of the values and ethics branch. Text version below:
Figure 12 - Text version

The Values and Ethics Branch organizational structure is as follows:

  • DG Values and Ethics – EX-02;
  • 2 AS-02 Administrative Office and Assistant;
  • a Director Internal Disclosure (AS-07) supported by a Senior Internal Disclosure Officer (AS-05);
  • a Director ICMS (EX-01) supported by 2 AS-06 Conflict Advisors and,
  • an Ethics Advisor (AS-07) supported by an Ethics Officer (AS-03)

The proposed budget of the Values and Ethics Branch for 2006/07 is $900,000, which includes funding for 10 FTEs and an O&M budget of $100,000 for awareness and communications activities, and potentially the implementation of pilot projects.

Functional responsibilities of staff members

Element/Positions Summary of roles and responsibilities

Commissioner

  • Set high-level expectations
  • Provide leadership and be visible in support of values and ethics
  • Respond to advice and recommendations from the ethics and values committee
  • Set the goals/framework in driving the culture change of the organization, including making the necessary investments

Senior officer and director general of values and ethics

  • Assess risks (including ethical risks) and gaps and mitigation strategy
  • Leadership of the ethics agenda
  • Ensure the effective design and implementation of the ethics agenda
  • Resolve dilemmas
  • Work with external advisors and central agencies
  • Administrative investigations, internal disclosure, Informal Conflict Management System

Ethics and values committee

To provide advice and guidance to the Commissioner and CSC's executive; to provide a forum of discussion; and to review internal disclosure investigation reports for organizational implications. The committee meets every three months. There are internal and external members of the committee.

Note – The role and membership of the committee may be changing to focus more on charting the direction for values and ethics and less on advice in individual cases.

Competencies are identified in the position description of the Senior Officer for Values and Ethics. In brief the competencies include:

  • Respect in the organization as having demonstrated values and ethics over an extended period of time;
  • Perceived as unbiased and credible;
  • Demonstrated strong leadership in promoting a culture of values and ethics;
  • Capability of "telling it like it is";
  • Investigation skills; and
  • Alternative dispute resolution skills.

How the model works

Employees have access to the full range of recourse mechanisms available to public service employees, as well as to advice and support through the Employee Assistance Program. Unions are an important part of this equation through their participation as advocates of employee concerns, and also in their participation in advisory committees. 

CSC promotes the accessibility of advice and formal recourse related to harassment, internal disclosure and labour relations matters, as well as the availability of employee assistance as a source of advice and support. Employee assistance coordinators and labour relations staff function at the regional level providing services, while other points of contact are currently provided from headquarters. 

Depending on the type of event or circumstance, investigations are handled by different organizations in CSC. Upon receiving a disclosure the Values and Ethic Branch will assess the inquiry and consider the need or not to refer it to another organization within CSC. For example, harassment complaints will be referred to human resource management for investigation and remedy. The Incident Investigations Branch deals with operational investigations such as escapes, offender assaults, etc. which are not the responsibility of the Values and Ethic Branch. Violations of the Values and Ethics Code for the Public Service (e.g., inappropriate conduct) are subject to administrative investigations by CSC, which depending on the nature of the issue may be conducted by the Values and Ethics Branch. The majority of cases are managed at the local/regional or institutional level, and certain cases may be referred to national headquarters for attention.

The Values and Ethics Branch provides advisory and investigation services usually for higher profile administrative cases that are considered best managed at the national level because of the seriousness of the event or the involvement of senior managers. One reason for this is that division has a reputation for neutrality, at least in part because of its co-location within the Performance Assurance Branch that houses the Audit and Evaluation functions. Any disclosures received by the Branch through the 1-800 line are handled in a formal manner as per the policy. Incidents reported to a departmental manager who then refers it to the Values and Ethics Branch will be investigated in a similar manger (i.e., assessment of the facts and recommendations). However, there is no mandatory requirement for managers to report incidents to the Branch.

The CSC established in 2003 an Ethics and Values Committee consisting of representatives internal and external to CSC. The mandate of the Committee was to provide advice and guidance to the CSC via the Assistant Commissioner Performance Assurance including the review of internal disclosure investigation reports for "organizational implications". The Committee was to meet every three months. The Committee terms of reference are now being reviewed. Revisions are being considered to make the committee more strategic in its orientation and less focussed on individual cases.

Overview: Practices for Integrating V&E in Organization Culture

Structure or process Current activities Factors for success

Leadership

The goal is to harness the leadership of executive and managers in the organization to be a model organization that engages in ethical best practices which encourage discussion of ethics at the executive and managerial "table".

The encouragement by leaders of dialogue on values and ethics at all layers of the organization is a vital factor of success. The department is seeking a culture change that is more accepting, supportive and less hierarchical. This requires a commitment of time and energy to ongoing dialogue among employees to explain why decisions are taken and the values and ethics considerations involved. As one manager put it:  Culture change is about getting people to work with you as a manager on problems as they come up. We want to be a model organization with open doors engaging in best practices and encouraging discussion of values and ethics at the executive table.

Policies and guidelines

The Code of Discipline governs staff expectations and staff behaviours. Standards of Professional Conduct have been developed.

It is not sufficient to have a policy. Commonly held expectations need to be set of what constitute both breach of policy and appropriate sanctions. The communication of case studies and dialogue on case studies contributes to the achievement of consistency in policy implementation. In addition, guidelines could be set on how the local/regional/ institutional levels can implement an effective ethics regime. This could include setting expectations regarding methods such as the frequency of meetings and the issues to be discussed.

Communications

Information is accessible through the "Let's Talk" article, and postings on internal and external websites. A Pamphlet on Internal Disclosure was distributed.

Informing employees and managers about how to access the right avenue for recourse is an essential aspect of communications. Beyond this communications focuses on awareness building about values and ethics.

An awards program for values and ethics would be a useful addition to the program to highlight successes and examples of good behaviour.

Learning

Learning includes:  A mandatory course entitled Ethics in Corrections; Executive development symposia (EX conferences); and the new Employee Orientation Program. Participants are required to read the CSC Mission – Values and Ethics. CSC provides ethics training for all recruited correctional officers. A conflict management module is used in the training of middle managers.

A national joint training standard was introduced for anti-harassment training for all employees.

A number of ethical decision models have been developed, taught and applied in practice. When the delegation instrument was developed for HR authorities the decision model was sent out to managers to help them make values-based decisions.

There is a need to move from 'monologue' to dialogue. If values and ethics are regularly talked about and are part of decisions and meetings then it can be said that this is strong evidence it has been integrated into the culture of an organization. Good ethical behaviours need to be modeled and publicized. There also needs to be ongoing dialogue and discussion about ethical risks. 

Staffing

Staffing for executives is assessed against the Leadership Competencies Profile, which includes a values and ethics component.

Defining a cost-effective method for validating the values and ethics of recruits or new incumbents is a difficult challenge.

Staff performance evaluation

 

For management staff, performance should incorporate a full range of considerations and indicators evaluating the ethical climate of the institution or organization.

Plans

 

A framework for the implementation of the ethics program is essential. This will emanate from a mission and vision and answer the following question:  What do values and ethics mean for our day-to-day work and where are we vulnerable?

Organization

The organization structure is being developed and continually refined since its recent establishment in March 2006.

Organizational independence was an important consideration in situating the Values and Ethics Office within the Performance Assurance Branch.

The ideal organization could include the additional element of ethics advisors to:  a) be a coach and counsellor on ethics; b) be a primary point of contact to refer staff to recourse mechanisms; c) gauge the ethical climate; d) advise the wardens regarding the development of the values and ethics program; e) provide training; and f) even provide an early warning of ethical concerns. An important consideration is that the advisor be trusted, and considered credible.

Committees/ Working groups

The Ethics and Values committee functions in an advisory capacity. The terms of reference for the Ethics and Values Committee is being updated to focus more on strategic direction than the treatment of individual cases. Other employee/union committees exist that provide useful information on the values and ethics climate of the department

Committees should function in an advisory and oversight capacity, charting and verifying the direction taken in values and ethics within the organization.

Risk management

The Values and Ethics Branch will have a role in reviewing policy documents to determine if they are "ethical" by being in keeping with CSC values.

Previous efforts to mitigate risk focussed on verifying and certifying compliance. Wardens were required to certify that everything they had done complied with policy. This requirement was found to be too onerous and unproductive.

The review of draft policy should include an ethical risk review to ask the essential question:  Are we addressing all the ethical risks involved in pursuing a policy?

There needs to be ongoing dialogue and discussion about ethical risks. This could include a risk management checklist about the factors/considerations involved in decisions (e.g., risk of absenteeism, reduced productivity, legal liability, harassment complaints).

Performance measurement and reporting

CSC participated in the Public Service Employee Survey. A coordinated response is being planned with union representatives. The OAG in its recent Proper Conduct of Government Business audit surveyed staff about ethics and ethical leadership.

Fully gauging the ethical climate of an organization requires access to survey information, and also hard data. Within a more decentralized organization, the challenge is to tap into all the data that is available particularly at the regional level.

Surveys provide benchmarks as a baseline that can be assessed through later surveys. Surveys could be implemented at the local level so that results can be assessed institution by institution.

Beyond surveys there is a need to develop a sound understanding for the reasons why staff have certain perceptions or why statistics point to values and ethics concerns within a given organization. 

There is also a challenge to provide balanced reporting within departments and the government. Instead of immediately holding departments to account for a few indicators (e.g., harassment complaints) central agencies should "step back" and consider attributes of good management that include, but are not limited to a few indicators.

Recourse mechanisms

Standard disclosure mechanisms are in place for internal disclosure (e.g., toll-free line, e-mail and fax).

The results of investigations need to be made known (within the boundaries of confidentiality).

8.0 Library and Archives Canada (LAC)

Figure 13: Library and Archives Canada Governance Model for Values and Ethics
Library and Archives Canada Governance Model for Values and Ethics. Text version below:
Figure 13 - Text version

Under the LAC governance model the Director Corporate Performance and Information is the Senior Official for Values and Ethics and reports to the Director General Corporate Management who in turn reports directly to the Deputy Minister. The Director Corporate Performance and Information has an indirect report to the Deputy however, for all relevant matters.

The Director Corporate Performance and Information is responsible for matters concerning:

  • Code of Values and Ethics
  • Internal Disclosure
  • Political activities
  • Internal conflict management
  • Gifts/hospitality
  • Audit
  • Evaluation

and manages the Director of HR who oversees Labour and Staff Relations within the Department (including Conflict of Interest and Harassment).

Values and Ethics Management Initiative

Role: To help support the decision making process throughout the institution.

Scope: Code of Values and Ethics of the Public Service, and Modern Management Agenda.

Primary Activities: Case and conflict management, values management, training and awareness, integration of values in decision-making, leadership through champions and committees.

The model identifies linkages inside the organization including:

  • Human Resources – Labour Relations for ongoing values and ethics work including in cases;
  • Human Resources Committee (sub-committee of management board) – direction setting;
  • Transformation team – direction setting for integration of values in the transformation exercise;
  • Department of Justice – Workplace Conflict Management Centre

The model also identifies linkages outside the organization with:

  • CSPS
  • PSHRMAC Office of Values and Ethics
  • Heritage (Senior Integrity Office) EPAC

For the purpose of: attendance at courses; advice; and Ombudsman type services and networking.

Governance model

"Integrating values and ethics in the organization culture"

Evolution of LAC values and ethics model

The merger in 2003 of the National Archives and the National Library created a unique organizational culture founded on distinctive professional communities, each with its own professional values and codes of ethics. The creation of a shared organizational culture is important to creating a climate of trust, integrity, and accountability. In the context of LAC the significant representation of professional communities requires finding the values they hold in common and ensuring that guidelines are provided for balancing potential competing/conflicting values.

The evolution of LAC's Values and Ethics Initiative was shaped by a number of considerations. The formation of LAC in 2003 was accompanied by an extensive consultation process, including the set up of internal working groups for clarifying the institution's mission, business lines, and functioning models. One of the recommendations that came from the analysis of the reports tabled by these working groups, in light of modern management principles was that "…LAC initiates a collective debate on the public service values and its economic, social and cultural role to eventually provide staff with clear guidelines regarding the values that have been officially recognized by the institution."Footnote 4  Part of the rationale for this recommendation was the requirement that both managers and staff members make the values and rules that govern decision-making explicit and openly shared.

Following from that recommendation a team from the Corporate Performance and Information Division of Corporate Management Branch was engaged in the development of a Values and Ethics Conceptual Framework and action plan. The consequent approach to values and ethics is premised on a clear differentiation of the two concepts and the subsequent processes that govern them. It is further concerned with the practical application of values and ethics to decision making from a management perspective. Thus the approach is centered on dialogue, awareness building and guidance.

The ethics component of the approach is consistent with central agency policies, the MAF and the Code for the Public Service. The values component, however, is customized to the organizational culture and context of LAC and is geared more specifically to its professional communities. It involves a consultation process for the clarification of the values held by LAC, development of case studies, the creation of a discussion forum and the development of decision-making tools.

Considering the nature of the organization, its relatively small size and low ethical risk, the creation of a formal Values and Ethics Program was not considered necessary. Instead the organization has developed a Values and Ethics Management Initiative.

Outcomes

  • Build a clear conceptual understanding in employees of the distinctiveness of values and ethics issues
  • Provide guidance with regards to balancing multiple values sets/sources with a particular focus on the professional communities and interactions with external stakeholders
  • Integrate values and ethics into decision making
  • Facilitate managers' understanding of their role and responsibilities associated with values and ethics
  • Ensure that the subsequent organizational culture is reflective of its lived reality, that is of its practiced values, mandate and goals

Organization structure of ethics governance

The organization structure is outlined in the chart below. The responsibility for developing and integrating values and ethics into the workplace falls under the Acting Director, Corporate Performance and Information. Under the Acting Director is a Senior Project Officer responsible for the Corporate Risk Management Framework and Modern Management. There is also one FTE engaged in full time ethics research. The LAC Values and Ethcis Governance organization structure consists of a Director of Corporate Performance and Information – Senior Official Values and Ethics (EX-01), a Senior Project Officer (PM-04) and a Research Officer Values and Ethics (ES-02).

Figure 14: [Image Caption]
Organization structure of ethics governance. Text version below:
Figure 14 - Text version

How does the initiative work?

Values component Ethics component
  • Values clarification strategy- identification of the values held by LAC; building consensus and support by senior management
  • Case studies- awareness building; building support capacity for decision making throughout the institution; geared towards the professional communities
  • Communication Strategy- Discussion forum via Intranet; workshops; orientation sessions for new employees
  • Tools
  • Internal disclosure
  • Harassment
  • Conflict of interest
  • ATIP

Ethics initiative overview:  Practices for integrating V&E in organization culture

Structure or process Current activities Factors for success

Leadership

The transformation document entitled Directions for Change recognizes strengthened leadership as a key driver of realizing LAC's vision.

The Proposed Values and Ethics Conceptual Framework for LAC recognizes the importance of leadership, which is "people oriented, inclusive, and encourages dialogue and learning."

 

Senior management team work effectively together in an atmosphere of mutual respect.

Select, support, and promote ethical leaders.

Process/Practices

Integration of ethics initiative with modern management

Seen to be clear, practical, relevant, and helpful by managers

Communications

Proposed model for Intranet portal on LAC values and ethics

Ethics discussed in orientation of new employees

The intranet portal ought to be informative, help refer individuals to appropriate areas, be interactive and stimulate dialogue

Learning

Values clarification consultation

Case studies proposed

Management support activities proposed

Values consultation should be as inclusive as possible, representing different functional areas, hierarchical levels, and cultural backgrounds.

The case studies and management support activities should be relevant and engaging.

Staffing

Attention to be paid to values and ethics criteria in staffing

Good evaluation tools with clear and consistent criteria.

Exec performance evaluation

Based on MAF indicators

Consistent and transparent interpretation and application of indicators

Tools

Decision making tool proposed

 

Case studies planned

Decision making tool should be succinct but cover a wide range of ethical issues. Training to support application of tool is necessary.

Cases need to be relevant and engaging.

Plans

LAC Approach to Public Service Values and Ethics

Directions for Change, Internal Strategies to Support Directions for Change implicitly identify central organizational values and strategies to realize these values.

Being honest and realistic about what can be accomplished

Recognize that values clarification and evolution is a long term project

Values development must be inclusive.

Organization

See chart

Matters of advice and recourse should be kept separate from learning, policy and ethical engagement.

 

Committees/ Working groups

HR Committee provides V&E oversight

Accessible to those involved in developing the ethics initiative, provide clear direction

Risk management

The ethics initiative, in its integrative approach, reflects the approach of risk management.

 

Ensuring that ethics and risk management is part of every managers' responsibilities

Performance measurement and reporting

 

 

Recourse mechanisms

Disclosure, proposed MOU with Heritage for Ombudsperson services

Employees need to be aware of the location and variety of recourse mechanisms.

Recourse must be accessible. 

Other initiatives (e.g., integration)

Values and ethics will continue to be part of the transformation initiative and modern management

Collaboration and integration will be crucial in shaping success

9.0 Nexen Inc.

Figure 15: Nexen Inc. Governance Model for Values and Ethics
Nexen Inc. Governance Model for Values and Ethics. Text version below:
Figure 15 - Text version

The Nexen Inc. governance model identifies the Board of Directors, President nad Chief Executive Office, Legal Group headed by a Chief Legal Officer and an Integrity as all contributing to and having responsibility for values and ethics within the company. All are participants on Board Committees - particularly Audit and Conduct Review – and are members of the Integrity Issues Committee, although they each have specific roles within the organization:

  • Board of Directors – regular reporting to and from the committees;
  • President and Chief Executive Officer are responsible for the approval of integrity policies and matters of concern and are informed of reporting to the board;
  • Legal Group/Chief Legal Office are responsible for investigation;
  • Integrity Coordinator provides services with respect to the policies identified in the Integrity Program and is responsible for investigation and program implementation.

Integrity Program

Role: Provide employees with tools and resources to integrate ethical business conduct into everyday decisions. Act as a resource for employees and other stakeholders regarding the integrity issues they have, as well as the provision of training, compliance, case management and investigations.

Scope: policies and procedures with respect to anti-trust, community investment, competition, computers, confidential information, conflict of interest, corporate governance, employee/labour relations, environmental conservation, ethics, external communications, human environment and social responsibility, security, and trading in company securities.

Primary Activities: Case and conflict management, values management, training and awareness, integration of values in decision-making, leadership through champions and committees.

The model identifies linkages inside the organization including:

  • Depending on the policy area, either of the following groups will undertake an investigation: HR, Audit, Legal, Corporate Security, Government Relations, and Comptroller. The Integrity Coordinator counsels the complainant regarding the need for investigation and then works with the Integrity Issues Committee to identify which group and officer will conduct the investigation.

The model also identifies linkages outside the organization with:

  • Corporate Ethics Management Council of the Conference Board of Canada
  • Canadian Business for Social Responsibility
  • Ethics Officer Association
  • IPIECA Social Responsibility Working Group
  • World Petroleum Congress.

The purpose of these linkages is to broaden professional skills and ethics best practices and norms.

Governance model

 "Integrating values and ethics in the organization culture"

Evolution of ethics model

Nexen Inc. is an independent global energy company listed on the Toronto and New York stock exchanges under the symbol NXY. The company was formed in 1971 and was originally known as Canadian Occidental Petroleum Ltd. Nexen has approximately 3,300 employees worldwide. 

Nexen's core business activities are to explore, develop, produce and market crude oil and natural gas. Nexen indicates it adds "value for shareholders through successful full-cycle oil and gas exploration and development, and leadership in ethics, integrity and environmental protection."  Its core oil and gas business locations are:  Yemen, Gulf of Mexico, Canada, North Sea, Long Lake (Canada), and Syncrude (Canada). Nexen also has a 61.4% indirect interest in a chemicals business, which was restructured into an income trust, Canexus Income Fund, in August 2005.

Nexen is a well-recognized example of private sector practice in Canada of ethics programming. An integrity (ethics) program has been in place since the 1990's. The company also helped develop the International Code of Ethics for Canada Business in 1997. The company has been the recipient of ethics awards (e.g., B.C. Ethics in Action Award).

The company maintains that "integrity is not just a value [at Nexen] – it's a way of life."  The company believes that its reputation as a principled company is the result of sound training programs, recruitment of top quality staff and open communication lines between the company and its stakeholders. "This approach has helped us achieve financial success, employee satisfaction and excellent shareholder value." 

Objectives/Outcomes of integrity program

  • Provides employees with tools and resources to integrate ethical business conduct into everyday decisions.
  • How employees interact with stakeholders and make sound decisions that respect company values, people, communities, the environment, safety and the law.
  • Promotes awareness of the International Code of Ethics for Canadian Business, company core values, and company policies.

Organization structure of ethics governance

In the Legal Group is found the Safety, Environment and Social Responsibility Department (SESR) headed by a Vice-President. The Integrity Coordinator works within the part of SESR responsible for social responsibility headed by a Director. The Integrity Coordinator has responsibility for coordinating the implementation of the integrity policies of the organization, as well as embedding integrity considerations in the workplace. In addition to integrity, Social Responsibility covers such matter as community relations, human rights, and corporate donations. 

Notwithstanding these reporting relationships, the Integrity Coordinator works directly with the Chief Legal Officer and the Director of Internal Audit when an integrity issues appears. As a group they form the Integrity Issue Committee, which decides how to resolve an integrity issue. 

How the model works

The following table describes the key elements of the program.

Element Summary

Chief legal officer

Leads investigation process as described in the pages below. The Chief Legal Officer a conduit of ethics concerns from employees. The Officer oversees policy compliance in consultation with senior management, and ensures that senior management and the Board of Directors receive regular reports on ethics concerns and investigations. Aside from employee complaints the Chief Legal Officer may receive a reporting attorney's report of a material breach of securities law or material breach of fiduciary duty or similar material violation.

Integrity coordinator

Oversees efforts to promote an ethical work environment and is accountable for developing and managing integrity and business conduct programs. The position ensures all integrity-related concerns brought forward are investigated and resolved, and periodically reports to senior management and the Board. The coordinator is one of the potential conduits of ethics concerns for investigation.

Integrity leaders

Senior managers in all parts of Nexen operations who as leaders help fellow co-workers interpret and understand company policies and discuss any integrity-related concerns. They work hand-in-hand with the Integrity Coordinator in championing the integrity program, and can also be the conduit of ethics issues to the coordinator.

Integrity issues committee

See description below. The investigation committee designate an investigator to investigate a complaint. The committee also communicated its findings and intended actions.

Investigators

Investigators assess integrity issues raised by employees to determine if they merit action and then propose the actions needed to resolve the issue. They may often prepare a written report.

Board committees

Employees may also direct complaints to the Chair of the relevant Board Committee (e.g., Chair of the Compensation and Human Resources Committee for behaviour which may constitute harassment).

Case management system

Every issue is placed within a case management system, describing the nature of issue, the process, information prepared and the action taken. The same external provider managing the system manages the Integrity Hotline. This ensures that issues raised through the Hotline can be downloaded and tracked in the case management system. Integrity leaders in remote locations can gain access to the case management system in a confidential manner without resorting to public forms of communication. The goal is to ensure there is a reporting system and paper trail regarding the type of issues handled and the steps involved in their resolution.

Compliance

Each year employees, contractors and senior and executive management must review and sign an Annual Statement of Compliance, acknowledging they have complied with key company policies. All newly hired employees and contractors must review and acknowledge they understand the company Conflict of Interest and Prevention of Improper Payments Policies. 

Integrity training

All new employees are introduced to the Integrity Program through mandatory integrity training. This training addresses company views on integrity, company policies, and integrity-related case studies. Workshops on Prevention and Improper Payments are also provided. The company has introduced integrity-related, online training for employees. 

Integrity evergreening

The program was launched in 2000. To ensure the program stayed relevant and current, an Integrity Evergreening review process was introduced in 2004. Through focus group sessions, an online survey and discussions with Integrity Leaders, employees addressed company integrity risks, challenges, best practices, and the program's vitality. Many recommendations from the Evergreening report were implemented. The major changes as part of the evergreening were the introduction of the hotline, revamping of the integrity workshop, development of a case management system, and the implementation of an automated on-line process for signing the Annual Statement of Compliance by every employee and contractor in the company. In June of 2006 Nexen is bringing all the Integrity Leaders together in an Integrity Forum to train them on the case management system and the compliance process. They will also discuss how to define integrity issues, aided by senior management presentations and perspectives on integrity. It is hoped that this will be an annual forum.

Reporting

Employees and other stakeholders are invited to report activities that may involve unethical, illegal or otherwise inappropriate behaviour such as:  a) violations of the law; b) violations of company policies; c) accounting or audit irregularities; d) risk to company assets, property or resources; e) danger to an employee's or the public's health or security; and e) concerns about other Nexen business practices.

Nexen expects that all employees will report perceived or actual: violations of the law; violations of Nexen company policies; danger to an employee's or the public's health, safety or security; risk to Nexen-owned assets, property or resources; or accounting or auditing irregularities.Footnote 5When an integrity-related concern is raised Nexen investigates as follows:

  • The Chief Legal Officer and Integrity Coordinator will be notified and one or both of them will coordinate the investigation.
  • Depending on its nature and severity, the concern will be referred to an Investigation Committee of three designated individuals. This committee ensures "prompt, fair and unbiased resolution of the concern."Footnote 6

An employee with a concern regarding questionable ethical practices is encouraged to submit the concern (complaint) to his or her supervisor, to the Integrity Coordinator, to an Integrity Leader or to the Chief Legal Officer. All concerns (complaints) will be reported to the Chief Legal Officer to handle the coordination and resolution of the complaint. At the direction of the person making the complaint, the Chief Legal Officer will refer the complaint to an Investigation Committee, which shall consist of three persons. As indicated above, employees may also direct complaints to the Chair of the relevant Board Committee.

The Investigation Committee will designate an appropriate person responsible for investigating and resolving the Complaint in a prompt, fair and unbiased manner. The investigation may proceed through an informal meeting with the person making the complaint. If the complaint cannot be resolved informally or if such a meeting is inappropriate, the person making the complain will be asked to sign a written complaint detailing the nature of the complaint, which will be made available to the other person(s). The investigator will then thoroughly and promptly investigate the matter in the manner directed by the Investigation Committee. When the investigation is complete, the Investigation Committee will communicate its findings and intended actions to the person making the complaint and the other person(s) regarding:  corrective action measures, unsubstantiated complaints, protection against relation, confidentiality, other avenues of recourse (e.g., if a regulatory body becomes involved). The Chief Legal Officer shall ensure that there is a record of the nature and treatment of the complaint and that the Board is provided a summary of such complaints at each regularly scheduled Board meeting.

Factors of success:  Practices for integrating V&E in organization culture

The following factors of success for the Nexen Integrity Program were identified:

  • Policies - The company maintains a series of policies applicable to all areas of risk and ensures compliance through well-understood processes.
  • Leadership - Support from top (president and executive team). They are constantly talking about integrity and are willing to invest in the integrity program. For example, an investment is being made to host in Canada a forum of the Ethics Leaders from around the world. Management has also invested in the case management system.
  • Accessibility – Having people available to answer inquiries at all times and provide an immediate response.
  • Reinforcement – The goal is to ensure ongoing visibility of the Integrity Program through innovative communications, compliance, meetings and awareness building. Dialogue with and among staff about integrity issues is a vital aspect of reinforcement activities. The overall goal is to develop a culture where people understand the importance of integrity issues and appreciate that there is an environment of openness for integrity discussion and disclosure.

10.0 Summary analysis

10.1 Introduction

The Directorate of Liaison, Evaluation and Accountability (DLEA) in the Office of Public Service Values and Ethics (OPSVE) at the Public Service Human Resources Management Agency (PSHRMAC) undertook a study of governance structures and practices in managing values and ethics (V&E) in the federal public service. The study was commissioned to provide departments and agencies, that are either just starting out or that are re-evaluating their own governance structures, with guidance on governance models and considerations to assist them in making informed decisions about what might work best within their organizations.

Governance refers to the processes and structures that any organization uses to direct and manage its general operations and program activities. This study focussed on developing governance profiles of seven federal government departments and one private sector organization. 

In this chapter we provide a synthesis of the key features of the governance of values and ethics from the profiles presented in earlier chapters. This synthesis is designed to offer insights into the fundamental expectation for success in a values and ethics organization found in the Management Accountability Framework (MAF) of Results for Canadians:  Through their actions, departmental leaders continually reinforce the importance of public service values and ethics in the delivery of results to Canadians (e.g., democratic, professional, ethical and people values)

In comparing the existence and application of governance structures in the profiles a key question was:  How can values and ethics become integrated in the culture of the organization to effectively influence the day-to-day behaviour of employees?  The focus of this study has been on the practical measures needed to achieve this goal. In this respect this chapter presents the following summary analysis:

  • Overall structure of V&E - How and why various areas of responsibilities were situated within their organizations, including:
    • Location of values and ethics responsibilities in the organization structure
    • Reporting relationships of values and ethics offices
    • Role and function of Committees
  • Structure of V&E offices – How the offices tasked with values and ethics responsibilities were organized, including:
    • Organization structure
    • Key responsibilities
    • Staffing levels and classification
    • Competencies required
    • Important linkages
  • Strategic considerations for the establishment of values and ethics functions – A key challenge for departments and agencies is deciding on the right governance structures and functions. The profiles revealed various strategic considerations important to the establishment of the functions.
  • Practices for integrating or integrating V&E in the culture of organizations – The study team considered the role of practical measures for ensuring the following key features of governance are effective:  Leadership, policies and guidelines, communications, learning, staffing, staff performance evaluation, tools, plans, risk management, performance measurement and reporting, and recourse mechanisms.
  • Ensuring the progression of the governance structure of values and ethics – A full range of practices may be vital to the success of the values ethics function, but available resources and capacity to absorb change requires a gradual and phased approach to culture change. This summary presents a phased approach to implementation.

10.2 Overall structure of V&E

Most stand-alone V&E offices designated with formal responsibility in this area are situated within risk/audit/assurance organizations. In some cases, some or all of their functions may have been a part of a Human Resources Branch, but this changed as greater prominence and resources were invested in values and ethics. The establishment since 1996 of stand-alone values and ethics offices usually resulted in the offices being located outside of HR within Risk/Audit/Assurance organization. This reflects many considerations, including the ascendancy of Modern Comptroller concerns, which included a significant focus on managing risk, including ethical risk.Footnote 7  Recent incidents of ethical breaches in the federal government have lead to further interest in establishing or expanding the role and resources invested in stand-alone values and ethics offices.

Generally, different decisions have been made regarding the appropriate distribution of responsibilities between HR and Risk/Audit Branches. The table below shows the policy roles of values and ethics offices profiled in this study (denoted by an "X"). Where the policy role is not vested in the office we identify the organization involved (e.g., HR or RA for Risk/Audit/Assurance, and Other).

Table 1:  Location and policy responsibilities of V&E offices

Policy area DND DFAIT HC PWGSC RCMP CSC LAC Nexen
Location in organization RA RA RA RA Stand-Alone RA RA Legal
Code of values and ethics (advice) X X X X X X X X
Internal disclosure X X XFootnote 8 RA X X X X
Conflict of Interest (COI) XFootnote 9 X HR HR OtherFootnote 10 X HR X
Gifts and hospitality X X HR X Other X X X
Post-employment X X HR HR X X N/AFootnote 11 N/A
Political activities X X HR HR Other X X N/A
Informal Conflict Management System (ICMS) HR HR X1 HR Other X X HR
Harassment HR X HR HR HR HR HR X
Employee assistance programFootnote 12 HR HR HR HR HR HR HR N/A
Human rights HR HR HR HR ?   HR X

From the table and the fact finding a number observations emerged:

  • All V&E Offices are responsible for Chapter 1 of the Values and Ethics Code for the Public Service and therefore, generally for supporting the Deputy Head to 'exemplify' values and ethics and to 'infuse' values in "all aspects of the work of their organizations."  As such, all organizations build awareness of values and ethics through communications, training and advice giving.
  • There is a usually a key decision point by senior management whether to invest in the values and ethics office a role in internal disclosure and more broadly in conducting investigatory work in support of policies. Most of the organizations profiled had responsibility for internal disclosure or were organizationally situated close to internal disclosure to achieve appropriate synergies.
  • Conflict of interest, post-employment, and political activities require similar analytical, policy and advisory skills. Often these policy areas are assigned to the same officer(s).
  • The location of ICMS varies across the profiles. Interviews suggested a causal relationship exists between organizational wellness, ICMS, and employee assistance. Values and ethics were considered integral to the achievement of a 'healthy' or 'well' organization and the minimization of conflict. Organizational wellness can be assessed through surveys and statistical analysis of the full range of indicators of wellness (e.g., harassment, conflict, absenteeism, etc.)
  • Harassment, which historically preceded V&E initiatives, is traditionally located in HR.
  • In all of the observed profiles line reporting to the deputy minister is mediated through another executive office. It should be noted that in all cases heads of the V&E Offices had ready access to the deputy minister on an informal basis, and for internal disclosure on a formal basis.
  • Many profiles revealed the presence of senior level committees (ADM level) that shared values and ethics considerations with other matters such as audit and evaluation/assurance. Generally, the role of the committees included one or more of the following main types of activity: a) discussing individual cases; or b) considering the overall 'health' and progress of the values and ethics program. Given the recent increased attention and investment in values and ethics and the gradual rise in number of V&E cases some departments are creating committees, which would have an oversight and coordination function of values and ethics functions.

Interviewees expressed both advantages and disadvantages of stand-alone senior management values and ethics committees. The argument in favour is that the committee can focus exclusively on values and ethics, which has been a topic of discussion crowded out because of an immediate emphasis on audit reports and other demands. Many values and ethics programs are in the process of either renewal or a building phase, which requires greater discussion, collaboration and buy-in at senior levels for planning and implementation. Some departments have relied on an existing senior management committee for this purpose, and others have utilized a stand-alone ethics committee. The arguments against having a stand-alone V&E committee are primarily that committee deliberations will be separated from discussions and decisions about important contextual frameworks such as policies, plans (strategic and business), risk, audit, and control. These considerations are crucial elements of monitoring and managing ethical risk, which will then have to be discussed at working levels.

A second type of committee, which operates at middle management, is an Ethics Advisory Committee. This type of committee focuses primarily on awareness building among internal champions and sharing best practices. Interviewees found this committee useful for discussion and dialogue, particularly during the start-up of V&E activities, when the importance, key features and rolling out of the activities requires the active participation and buy-in of each departmental unit. In this phase there is considerable scepticism described by some interviewees as a "Mount Everest of scepticism" that must be surmounted. Interviewees indicated that a key success factor was the development of advocates throughout different units who could debunk any 'myths' or doubts regarding the value of the program.

A third type of working level committee being considered is a coordination committee to discuss individual cases. A frequent comment from interviewees was that employees seeking recourse might contact a variety of different functional areas concerning issues that cut-across areas of policy responsibility (e.g., harassment, conflict management and disclosure). In some profiles this concern has been handled informally through the regular contact that necessarily occurs between managers. In some instances because the workload is increasing there is consideration being given to establishing a more formal committee or working group with regular meetings among different managers covering the full range of V&E related policy areas. In the absence of this kind of arrangement some departments have found it convenient to establish Memorandum of Understanding between different operating areas so that case management protocols are clearly understood.

10.3 Structure and operational issues of V&E offices

The structure of V&E Offices varies across the profiles depending on their areas of responsibility as shown in the table below. Usually an EX-1 heads the office to ensure effective communication with senior management on sensitive matters. For larger departments the size of the core staff within the Offices usually numbers between 5 and 7. The total number of staff will vary according to level of risk of the organization, policy responsibilities and decisions about embedding values and ethics within operating units. The nature of the workload varies because of differing responsibilities, but the following generalizations can be made:

  • One or two staff classified at the AS or PE level are usually dedicated to case management and advice giving. In most cases these staff are classified as AS except in the case of DFAIT, which contains PE staff to manage harassment cases. In PWGSC PEs manage V&E related responsibilities such as Conflict of Interest that are handled by AS classified staff in other profiles. Most profiles relied on AS-6 or PE-4 level staff to handle the sensitivities of advice and case management.
  • Administrative tasks usually required one or two AS-1 staff members responsible for such matters as statistics collection and reporting, as well as coordinating central agency information requests.
  • Some V&E Offices retained specialized professional staff to ensure the work of other staff was well informed about unique professional conditions and ethical dilemmas. To be precise, in Health Canada, DND, DFAIT and RCMP, the V&E Office contained professionals from nursing, science, military, foreign service (consular) and enforcement.
  • Many V&E Offices ensured they retained a significant knowledge base in ethics theory and practice, particularly during the stages of program development, but also as an ongoing support to policy and program delivery. In departments or agencies where risk issues are paramount, organization sub-culture and professions are distinct, or where a high percentage of the workforce are professionals it was thought best to employ one or more officers with high academic standing in values and ethics. In organizations comprised of a high number of professionals it was thought that all officers should be highly educated. In cases where the need was not as great this expertise was contracted out. Advanced values and ethics expertise is in short supply. Many organizations ensured that staff received some accreditation (e.g., through a course) in ethics from an academic institution.
  • Smaller departments are more constrained in their ability to develop stand-alone V&E offices with dedicated staff. Although, this study focussed on large and middle-sized departments, some observations were possible regarding the approach taken with smaller organizations. Typically, in these organizations a V&E head dedicates partial time to V&E responsibilities and has, as in larger departments, similar reporting relationships (administratively to a senior manager, and for case management to the Deputy Head). Particularly, during the start-up of investment in a V&E program, it was considered essential that the V&E Head be supported by one full time V&E officer with a sound base of ethics knowledge, as well as contracted resources to supplement this expertise when required.
  • Budgets were divided between Salary and O&M. O&M was spent for a variety of internal purposes, but also in some cases for contracted support in the development of conceptual frameworks, advisory services in ethics, conduct of investigations, communication products and training packages.  Internal costs were focussed on travel and professional development. The costs for delivering training were usually borne by the participating organizations and not by the V&E offices.

Table 2:  Budget, FTEs and responsibilities of V&E office staff

V&E office DNDtable note 1 * DFAIT HC PWGSC* RCMP CSC LACFootnote 13 Nexen

Table 1 Notes

Table Note 1

Please note - Unlike PWGSC where all Values and Ethics personnel is financed by the Office of Values and Ethics budget, DND does not include personnel costs for Values and Ethics in other organizational units.

Areas of responsibility for office staff

Return to table note 1 * referrer

Personnel (FTEsFootnote 14

84,000

11,000

9,000

12,500

23,000

14,500

1,100

3,000

Total budget

($ 000's)

8,900Footnote 15

1,000

650

2,000

-

900

As needed

-

Salary

1,100

580

370Footnote 16

1,650

-

800

 

-

O&M

7,800

420

280

350

-

100

Not applicable

-

 

Total FTEs

7

5

5

5 Core
14 OfficersFootnote 17

5

10

2

2

Head – classification

EX-01

EX-01

EX-01

EX-01

AM-05

EX-02

EX-01

EX-01

Officer level

Staff – classifications

AS, CR, Military

PE, AS

EDSFootnote 18

AS

AS

AM, PSE, AS

AS

ES, PM

Officer level

Research, strategy, learning and communications

2-AS-5,

1 Major
(EX-1)

EDS-03  AS-06

AS-07 AS-06

2-AS-07

PSE

AS-07

AS-03

ES-02

PM-04

Officer

Administration, reporting/coordination

CR-3

AS-01

AS-01

AS-01

2-AS-02

AS-02

CR-04

ES-02

Officer

Policy, advice or case management

AS-7, 

2-AS-5

2-PE-04

 

AS-07

AM-03

AS-07

AS-06

2-AS-05

EX-01

Officer

Specialized expertise(e.g., professional cadre such as military)

2 MilitaryFootnote 19

1 MCOFootnote 20

 

14-AS06

 

 

 

 

To fulfill their responsibilities, some of the general competencies or capacities required of ethics officers included, but were not limited to:

  • Analysis - Developing and putting in place diverse policies and initiatives, including conducting policy analysis and related consultations.
  • Teamwork - Working effectively in teams, internally within the V&E office, but also very importantly to foster strong collaboration with management teams across the organization.
  • Management – Ability to provide advice and collaborate with senior management in implementing the values and ethics program and initiatives, including with respect to integrating values and ethics in management functions/practices.
  • Communications - Ability to develop awareness campaigns (training and communications), make presentations to large audiences and facilitate dialogue among staff and management regarding values and ethics.
  • Advice - Ability to provide counsel and advice, particularly to senior management, on all matters of values and ethics and policy, and ensure effective referrals of cases to the right locus of responsibility.
  • Investigation - Ability to conduct investigations in a sensitive, confidential manner, and to coordinate the disposition of the cases in collaboration with internal partners in the organization.

Interviewees regarded inter-personal communications as a crucial skill to ensure ethics officers are considered a knowledgeable, sensitive, and accessible source of guidance in the interpretation of values and ethics practice and policy. Interviewees were also clear that 'sensitivity' meant that staff should not be perceived as "judge and jury" paternalistically rendering decisions. Instead they should direct individuals to the right information and or help facilitate their decision consistent with policy and organization values. Ethics staff also needed to be self-starters capable of selling initiatives to senior managers.

10.4 Strategic considerations for the establishment of values and ethics functions

The establishment of new or enhanced values and ethics functions in a department or agency faces certain challenges and requires the resolution of some key considerations, including but not limited to:

  • Demonstrate a proactive approach to values and ethics: A key starting point is to identify risks to the organization, which can lead to the development of a well-communicated strategic roadmap identifying desired outcomes, responsibilities and means for achievement of a long-term sustainable values and ethics program. This would include a description of key areas of policy and program intervention and the investments that will be made year-to-year. In demonstrating a proactive approach senior management needs also to ensure there are advocates, including assigned personnel, visibly committed to values and ethics placed throughout the organization. What this means is that every organization needs:  a) a core complement of values and ethics officer(s) who provide the needed expertise and advice; and b) a committed cross-section of employees and managers who are values and ethics advocates.
  • Responsibility for policy: There are legacies with respect to the location of policy responsibilities related to values and ethics. When values and ethics organizations are established as stand-alone entities the immediate question is:  Which policies is the V&E Office to be responsible for? This requires strategic organizational decisions about restructuring responsibilities for policy areas previously managed by other units in the organization. Depending on the decision or the lack thereof, values and ethics offices may end up focussing exclusively on awareness building or relatively narrow concerns. This also may result in barriers for the integration of values and ethics in the working culture.
  • Leadership in alignment with organizational values and ethics:  Above all, leadership needs to be exercised by the Deputy Minister in ensuring buy-in by his/her executive team to the goals and plan of the values and ethics program. A key potential role for a values and ethics office is to provide an overview perspective and even oversight on the achievement of embedding values and ethics in work culture. First and foremost, this requires locating the values and ethics office such that it is and is seen to be a key advisor to the deputy minister and his/her executive committee. The profiles demonstrate this prominent location, although it is not clear the extent of substantive interaction with senior management beyond managing certain sensitive cases. Policies and practices throughout the organization need to be aligned with values and ethics including, but not limited to the following: the development of an oversight report evaluating the ethical climate and progress in values and ethics; the incorporation of ethics decision-making models in executive deliberations (including committees); considering values and ethics in the policy development and approval process; and the development and communication of a multi-year plan for investing in embedding values and ethics.
  • Setting the appropriate organization structure:  The organizational location of the ethics office is appropriately located strategically close to the Department or Agency Head. There is no standard recipe evident in the profiles for size of values and ethics organization and scope of policy responsibility. We understand that existing models have evolved for a variety of good reasons. In Table 3 below we list and describe the key functions reported in the profiles that are often shared among different units in departments.

Governance functions also include structures established for values and ethics support within regions and operational units. Many profiled organizations have established or are considering the establishment of a more robust presence within operational areas and regions. Features of this robust presence, particularly for larger and higher risk departments may include:

  • Ethics Advocates (Champions) – Some organizations have realized the benefits of supporting a cadre of senior managers who act as advocates for values and ethics within their organization units. They exemplify a commitment to values and ethics. The V&E Office provides advocates with advisory support and oversight on the integration of ethics into their operations. A committee or consultative group of advocates is often evident in the organizations profiled.
  • Ethics Advisors (Officers) embedded within operational units – Large organizations such as DND and PWGSC embed ethics into organization practices, ensure oversight, and provide ethics advice by placing advisors in each business line/geographical area. A values and ethics survey by PIPSC (Professional Institute of the Public Service of Canada) of its members identified the importance of having ethics advisors close to the people needing advice. Other organizations interviewed are very interested in this model because they, too, have identified the importance of values and ethics participation in the day-to-day discussions, decision-making and business processes of business lines. A consensus is developing around the need for ethics advisors to have a well-defined and supported relationship with the values and ethics office focussed on:  a) consistent advice giving; b) ethical climate assessment and values and ethics oversight (reviewing ethical climate and progress in embedding values and ethics); and c) provision of values and ethics services.
  • Fulfilling small agency needs - Small agencies require special consideration because they do not have the same size and resources. The profiles revealed that small agencies have found memorandum of understanding with other departments helpful in filling the needs of ethics responsibilities. For example, the Public Health Agency and Library and Archives Canada have Memoranda of Understanding (MOUs) with mother departments to provide ombuds-services, ethics services, disclosure and ICMS. Nevertheless, the profiles indicate that even small organizations have a senior officer who dedicates at least partial time to V&E policy delivery and program development. The profiles also suggested that a full time values and ethics analyst, at least during program start-up, is needed to support the Senior Officer.
  • Contracting out - Most organizations of various sizes have found it necessary to contract out values and ethics expertise needed on a temporary basis. Examples include:  a) conduct of ethical climate surveys; b) providing specialized training for specialized professional groups; c) development and delivery of training modules; d) foundation framework development (i.e., justification for developing an approach to organizational ethics, including development of organizational values which subsume values inherent in the professions and communities of the organization); e) performance measurement; and f) business plan development.

Table 3: Functions for Values and Ethics

Shared Core Values and Ethics Functions in Departments
Specialized Expertise Communications and Learning Investigations Advice Giving Policy and Research
  • Knowledgeable resource people in unique professions and areas of expertise
  • Intergration of Code of Values and Ethics for the Public Service and policies with professional norms codes and standards
  • Awareness building
  • Learning program Communications products and services (e.g., pamphlets, website)
  • Promoting dialogue and discussion amount employees and managers
  • Code of Values and Ethics for the Public Service(general)
  • Conflict of Interest
  • Gifts/Hospitality
  • Post-employment
  • Post-employment
  • Political activities
  • Foundation work (theory and practice applicable to the organization)
  • Integration efforts (progress in embedding)
  • Alignment of policies
  • Business planning
  • Performance measurement
  • Tools (e.g., decision tools)
  • Monitoring - including statistics
  • Harassment
  • Human Rights
  • COnflict mediation
  • ICMS
  • Employee Assistance
  • Ethical climate assessment (shared with Policy and Research)
Operational Functions (Operations and Regions)
Ethics Advocates Ethics Advisors (applicable to larger organizations) Ethics Committees
  • Senior managers in operational units who understand and promote values and ethics interventions
  • Liaise with values and ethics functions to acquire expertise, advise and direction
  • Values and ethics practioners and experts embedded in operational units
  • Provide various services such as oversight, advise, awareness building, training, etc. (depending on needs of the organization)
  • Type 1 - Senior management committee (direction, policy setting, oversight)
  • Type 2 - Ethics Advocates Committee (buy-in, input and sharing information)
  • Type 3 - Case Management Committee (coordinating case management)

Supporting Linkages

  • Communities of practice (inter-departmental)
  • Training Institutes in Government (Canada School of the Public Service, specialized training institutes in departments and agencies)
  • Academia (e.g., courses, accreditation)
  • Ethics practioners associations
  • Professional associations (e.g., engineers)
  • Private sector consultants

10.5 Practices for integrating V&E in the culture of organizations

The success of a values and ethics program is partially dependent on governance structures. Structure is needed to ensure activities occur in a strategic, consistent, and adequately resourced manner. However, structure must be supported with a successful program of initiatives for integrating values and ethics into an organization's policies, procedures and practices.  From their review of programs in the United States, Trevino and Weather in their book Managing Ethics in Business Organizations noted the importance of institutional or managerial influences.

Many organizations respond to institutional pressures by creating structures and practices that appear to satisfy external institutional expectations while actually leaving internal, organization behaviour untouched. Such responses constitute a kind of "window dressing," or organizational Potemkin villageFootnote 21. Much the same could be true about formal ethics programs. Organizations can do things that appear, on the outside, to be part of an effort to foster ethical behaviour, but on the inside those responses have little or no impact. Here again, we see differences in the role of institutional and managerial influences in explaining organizational responses…responses that are more likely to be deeply ingrained into organization practices reflect the commitment of top management actually to doing something to foster ethical behaviour.Footnote 22

Participants in interviews and focus groups identified key managerial influences or practices required to make public service values and ethics governance structures successful. Above all employees must be provided with opportunities to experience the application (integration) of values and ethics in their day-to-day activities (e.g. in planning or performance evaluation).  These opportunities must be sponsored, encouraged and, if necessary, mandated by senior management, all supported by regular and positive communications about the benefits. John Kotter in the book The Heart of ChangeFootnote 23 argues behaviour change in organizations can only come from direct experience and not the "telling."

People change what they do less because they are given analysis that shifts their thinking than because they are shown a truth that influences their feelings. This is especially so in large-scale organizational change…

We fail [at change efforts] because we haven't sufficiently experienced highly successful change. Without that experience we are too often left pessimistic, fearful, or without enough faith to act.

The table below summarizes from the profiles the factors for success in ensuring governance structures achieve a successful embedding of values and ethics in management practices. 

Structure or process Factors for success

Leadership

  • Support from top leadership is seen as the most fundamental element of an ethics program. Support means: demonstrating and also consistently and fairly enforcing good ethical behaviour; ensuring communications has the right positive tone and occurs at the right time; and ensuring resources are invested in developing and sustaining the values and ethics program.

  • Create an atmosphere in management committees where values and ethics discussion is welcome. Management committees should utilize ethical decision tools as a "lens" to apply in key decisions (e.g., procurement, policy, etc.
  • Communicate and support a multi-year plan for achieving the integration of values and ethics culture, which identifies a vision for values and ethics, and the actions and investments anticipated.   (See "Plans" below for additional information)
  • V&E must be renewed regularly through sponsorship of active dialogue among leaders and between their staff, as an ongoing aspect of the management agenda. This can include, but not be limited to interactive sessions with management teams in developing values and ethics strategies.
  • Find opportunities to reward ethical excellence such as an Award of Excellence for Values and Ethics. 
  • Mandate that organizational processes, including planning and risk management incorporate ethical risk assessment as a visible element. 

 

Plans

  • A values and ethics program needs to be guided by a multi-year plan.  The plan should set out a vision for the benefits and outcomes of the planned values and ethics program. The plan should detail the full range of activities and interventions to be undertaken during a multi-year period, and the anticipated outputs and outcomes.  The roles and responsibilities of all participants in the program should be aligned to the activities. The plan should make reference to the ethical risks that will be mitigated. Finally, the required expenditures in resources (HR and financial) should be detailed year-to-year.

  • Integrate values and ethics considerations in the planning of operational units – Opportunities exist to integrate ethical risk considerations and values and ethics initiatives into the business plans of operational units. Planning processes (e.g., retreats) and templates should include visible consideration of values and ethics.  Environmental scanning as part of the strategic planning process should incorporate consideration of values and ethics.

Policies and guidelines

  • Develop statements of values for discretionary behaviour

  • Develop policies and review existing polices with respect to the guiding principles of the program, particularly about values and ethics
  • Develop codes of conduct in areas of significant risk related concern and communicate these effectively.
  • Work with regulators and conduct dialogue sessions with professionals regarding the relationship between the code and professional codes (Public service values vs. professional values)
  • Develop a repository of guidelines and standards that all departments can utilize.

Communications

  • Outreach Strategy There should be an outreach strategy that would be adjusted through a stakeholder analysis

  • Employees need to see proof that the system is working through models that describe "heroes of behaviour" and case studies that relate to the practical working constraints of staff in each professional cadre.
  • Plain language and conciseness in messaging is essential to effective communications. This should include a product to communicate the V&E Code for the Public Service quickly and easily.
  • Advisory Services should utilize as many channels of communications as possible and be promoted extensively and in a creative way to encourage use of the channels.
  • Innovative practices must continue to be explored beyond the traditional: Posters, pamphlets, bookmarks, etc. Electronic messages with in-built videos were considered one possible innovation. Internet sites should be constantly updated and be as interactive as possible.
  • External communications - A program should develop a good strategic communications plan to identify risk, target audience (internal and external), and key messages.

Learning

  • Mandatory versus optional values and ethics training - There was considerable debate among participants in this study about the merits of mandatory vs. voluntary training in ethics. Some departments felt that a mandatory requirement would reduce the positive impacts of values and ethics training and discourage further interest in the program. Others were convinced that any negative perceptions created by mandatory training were outweighed by the benefits:  full coverage of all risk areas of the department; and trainees emerge from training with positive viewpoints and a commitment to values and ethics.

  • The promotion of ongoing dialogue within work units was considered absolutely essential to the progression of the values and ethic program. Sponsored by managers and supported by the involvement of the V&E Office, these dialogue session were considered very useful in exchanging ideas and approaches among peers. There were some opinions expressed that this dialogue could be encouraged as part of management commitments, and also through visible departmental investment in budgets for management functions like planning retreats.
  • Any course offered by the Canada School or within the department should contain a values and ethics component.  An introduction to values and ethics is the subject of stand-alone courses, but should be followed by the integration of ethics modules in standard training courses in HR, procurement, finance and other areas of professional practice. This would, in part, focus on creating a bridge between the consideration of rules and compliance with a value-based approach to ethics. V&E Offices need also to customize existing awareness and learning products for professional cadres such as nurses, scientists, military officers, enforcement officers, management, and the regulatory community.
  • Learning materials require continuous updating or they lose their appeal quickly.  Most importantly, case studies should be updated since they are core of the learn-by-practice approach that is essential for the full understanding and application to the work environment of ethics decision-making techniques. 

Staffing

  • Some department have a voluntary process of exit interviews for departing employees that is not uniformly implemented. Focus group participants believed this procedure could be normalized and the results made accessible.

  • Values and ethics considerations need to be integrated in staffing processes for new employees to the organization, but also for ongoing staffing actions. The extent to which this occurs is a challenge, but organizations should focus a disproportionately higher effort in job categories involving higher ethical risk.

Staff performance evaluation

  • V&E need to be integrated in the performance measurement of EXs and eventually into all performance evaluations.  Some departments identify V&E as one performance criteria, but recognize that there is a challenge in measurement. In the absence of any resolution of this challenge, a more immediate solution is to develop a checklist of the kind of measures managers need to put in place to promote a good ethics culture. This would include, but not be limited to measures such as:  Creating an ethical risk component of business plans, as part of risk assessment; ensuring risk management regimes incorporate risk; ensuring ethical risk training is part of training plans and are modules in training courses; piloting the use of ethical risk decision making tools; and conducting dialogue with staff about ethical dilemmas and decision making as part of regular staff meetings and retreats.

  • Competency profiles need to include values and ethics as a visible element.

Tools

  • Ethics decision-making tools should be a standard element of training modules.   Most values and ethics programs have developed a one-page ethics decision-making guide. During training participants are asked to utilize this guide in working through case studies. This is one key method for learning-by-doing.

Committees/ Working groups

  • The establishment of formal networks would permit the 'leveraging' of efforts to ensure the progression of the values and ethics program. V&E Offices have limited resources and cannot assume full responsibility for all awareness building activities. To assist in this effort V&E champions within organizations must be cultured by senior managers with respect to responsibilities and key annual deliverables (e.g. a plan of action, ethics climate assessment report, dialogue sessions, changes in operational practices such as planning). Especially, in the start-up or revitalization stages of values and ethics programs committees of champions from across the organization are needed to develop a consistent understanding and buy-in to the values and ethics program and plan.

  • Depending on the size of the organization and caseload the decision to establish a stand-alone senior management committee on ethics will vary.  For larger departments, it is more advisable that a stand-alone committee concern itself with values and ethics and contiguous concerns such as risk, audit, performance, etc. For smaller organizations, the management committee would probably need to fulfill values and ethics requirements.
     
  • A working level committee among managers to coordinate the handling of cases is only advisable if the number and complexity of cases is significant. Often informal methods (ad hoc meetings, telephone calls, etc.) work effectively.

Risk management

  • Collaborate with units of the organization and external stakeholders to ensure a good "fit" between fundamental values/goals and actual work practices. This would cover learning, but also importantly the integration of risk management practices. There is an opportunity for V&E Offices to participate in and leverage their efforts through the investments made in risk management. 

  • Risk management frameworks should incorporate inventories of potential ethical risks.  Audit, Assurance and Risk Groups are typically focussed on operational and 'reputational' risks. The level and type of ethical risk should be weighed across every organization in the department to inform plans, including training plans.

Performance measurement and reporting

  • Provide senior leadership with an oversight report evaluating the progress of organizations under their care in meeting values and ethics multi-year plan goals and tasks. The oversight report should consolidate statistics and other information to accompany a briefing of the Deputy Minister on the effectiveness of the values and ethics program. V&E officers should play an important role in assessing the performance of individual organization units, and their general state of organizational wellness. This can be done in a brief statistical and narrative form on an annual basis. On a three-year basis a full-scale evaluation of the success of the program should be conducted based on surveys and other more detailed methodologies. 

  • Assess the performance of operational units – Business lines should incorporate in their management reporting the following:  values and ethics performance measures (e.g., complaints); and a general assessment of organizational well being including the values and ethics "health" of their organization.
  • V&E Offices should develop as a key structure in their planning template a one-page results framework.  This would set the logical relationship between activities, deliverables (outputs) and the results (outcomes) anticipated. From this, planning would focus on determining the actions required for each activity, the timing and the resource requirements. In addition, metrics for performance need to be developed and then assessed once the program is in place and has been operating for a few years (e.g. in Year 3 of a multi-year plan).
  • There is a need to have tools to measure the "ethical climate", but they should not duplicate the PS employees' survey. If so, fatigue and lack of interest will set in. One option would be to conduct on a regular or even annual basis, short confidential surveys. 

Recourse mechanisms

  • The perceived accessibility or inaccessibility of recourse mechanisms needs to be addressed through tangible and innovative awareness building measures, but also proactive approaches to resolving emerging organizational 'unwellness'.   Focus groups clearly remarked on the psychological hurdle individuals must overcome before resorting to formal resource measures. Formal recourse usually represented the final stage of the frustration of employees. Therefore, the challenge for values and ethics programs was to go beyond formal disclosure, but consider the 'early warning' signs of organization 'unwellness' that suggest the values and ethics climate needs attention. There are common metrics that can be used (e.g., number of cases, turnover, etc.), but these needed to be consolidated from different parts of the organization into a regular report and regularly discussed in management meetings. 

  • The values and ethics office should provide feedback on cases, to provide clear examples or case studies of ethical dilemmas and how they have been effectively dealt with.  The V&E Office should solicit examples of cases from the department within the limits of confidentiality concerns. These should be shared as best practices, but also as examples of how the values and ethics program resulted in positive contributions to enhancing the ethical climate. It was a common concern voiced by interviewees and focus group participants that the follow-up on ethical concerns needs to be openly and effectively communicated.

The above table identifies many practical measures for achieve an embedding of values and ethics in management practices. The next section of this chapter places these measures within a phased plan for values and ethics program development.

10.6 Plan for ensuring the progression of the governance of V&E

This chapter presents the beginnings of an overall change management plan to achieve a long-term sustainable culture of values and ethics. A key culture change challenge voiced by interviewees was that the momentum and interest generated by initial awareness building efforts, must be sustained in the longer-term by: 

  • Integrating values and ethics in the working culture, and management practices of the department or agency; and
  • Demonstrating the importance and value of the V&E Office role and its practitioners

In the plan below we have identified where the Office of Public Service Values and Ethics (OPSVE) at PSHRMAC can assume an important role in collecting best practices, conducting research and encouraging the sharing of lessons learned government–wide.

Planning – Year 1

  1. Develop a theoretical framework of values and ethics, which includes a review of theory and its application to the professional duties and ethical dilemmas of staff
  2. Develop a vision for values and ethics (mission, vision and desirable outcomes)
  3. Conduct an ethics climate assessment
    1. Snapshot of current environment – including review of staff composition and assessment of the level of ethical risk in the organization
    2. Stakeholder analysis
    3. Identify factors of influence/success
    4. Gap analysis through surveys and focus groups – establish a baseline for outcomes that can be assessed some years later
  4. (OPSVE) Research best practices
  5. Business case development
    1. Climate and gaps
    2. Vision, mission, outcomes
    3. Risk analysis related to implementation to plan
    4. Options (values/compliance focus, organization structure, staffing, process, financial)
    5. Recommendations
  6. Presentation and decision making
  7. Design
    1. Detailed organization structure and HR Plan – consideration of values and ethics organization location and policy responsibilities
    2. TOR of governance structure (e.g., committees)
    3. (OPSVE)  Guidelines and policies
    4. Culture change plan
    5. Communications plan and initial products
  8. Engagement
    1. Advocates
    2. Establishment of network and consultative group for buy-in
    3. Advocates Committee
    4. Executive Committees

Roll-out – Year 2

  1. Put in place core team for Office of V&E
  2. Communications – demonstrate value-added, role and establish a visible presence
    1. Senior management introductions and plan
    2. Publicize code and guidelines/role of ethics officers
    3. Develop immediate infrastructure (e.g., 1-800 lines, web-site)
    4. Concept, visuals and products (e.g., pamphlets, posters, bookmarks)
  3. Training
    1. identification of population at risk and critical mass required in trained staff
    2. Establish training targets
    3. Develop values and ethics training modules and manuals (generic, orientation for new employees, managers and communities of practice)
    4. Integrate modules in other professional courses (e.g., finance, contracting, etc.)
  4. Awareness
    1. Introductions to management teams
    2. Presentations on role and functions
    3. Awareness building on dilemmas and decision making tools
  5. Implement advisory and case management services
    1. As per policy
    2. Develop codes of conduct for high risk groups
  6. (OPSVE) Performance and data measurement
    1. Identify information requirements
    2. Develop a results framework and performance strategy
    3. Develop report format
    4. Data collection protocols
  7. Develop integration plan and finalize in consultation with HR, Risk/Audit, and other groups
  8. Monitor progress of implementation and service delivery – development of first oversight report on the state of values and ethics in the organization.

Begin integration – Year 3-5

  1. Introduction of Evergreening and sustainability plan and program to ensure refreshing of program and integration of values and ethics practices in the working culture.
  2. Training
    1. Implement training modules or tailored made sessions for high risk (e.g., Procurement)
    2. Conduct stand-alone training for other lower at-risk employees
    3. Refresh training programs with new case studies
  3. Communications
    1. More extensive promotion (e.g., kiosks, newsletters, and other innovations)
    2. Best practices and success stories
    3. Constant investment in innovation
  4. (OPSVE) Develop oversight report on health of V&E (# and type of cases, progress in training, new tools, situations prevented, comments, new guidelines)
    1. Develop methodology for assessing ethical climate
    2. Conduct evaluation of V&E program using results framework
  5. Implement integration activities
    1. Risk management
    2. Participate in any reviews on controls frameworks to bring in ethical risk issues
    3. Performance evaluation
  6. Engagement
    1. Identify and implement management approach for investing in and encouraging dialogue
      1. Supported by managers as an ongoing activities
      2. Supported by the V&E Office

Appendix 1 – Interview guide

Background on study

The Directorate of Liaison, Evaluation and Accountability (DLEA) in the Office of Public Services Values and Ethics has undertaken a study of practices in managing values and ethics in the federal public service. The study is needed to provide departments and agencies, who are either just starting out or who are re-evaluating their own governance structures, with guidance on governance models and considerations to assist them in making informed decisions about what might work best within their organizations.

The study will: document various examples of values and ethics programs and their related responsibilities; elaborate several different governance models as potential practices; discuss the pros and cons of each; and make recommendations as appropriate.

Purpose of the interview

A key part of the fact finding for the study is the conduct of interviews and focus groups with a selected number of departments, agencies and private sector organizations. The goal of these interviews is to obtain opinions and information about what works best in developing an effective public service values and ethics program. During the interview we will also discuss the arrangement of a focus group with selected staff in your organization.

The Directorate has engaged the Business Facilitation Group to complete the interviews. Each interview will last between 1½ hours. 

  1. Outcome - What is the vision or end outcome(s) of your department's values and ethics program?
  2. Overall Elements - What do you see as the key functions or elements of your organization's values and ethics program? (The consultant will develop a graphic of this in discussion with you.)
  3. Organization Location - Organizationally, where does the Values and Ethics function reside in your organization (both at HQ and in regions)? What are the advantages of this current location?
  4. Responsibilities - What is the scope of responsibilities for the Values and Ethics (V&E) office of your organization?
  5. Linkages/Relationships – what is the nature of the linkages/relationships your V&E practitioners have with other parts of your organization? What assistance, if any, does your V&E program rely on from outside your organization?
  6. Embedding Values and Ethics in the Organization – What practices are most important in ensuring values and ethics are embedded in the everyday practices of your organization?
  7. Formal Structures - If you were to start your program again how would you structure or organize it? What would be the first things you would do? What would you do later? How would this be different from your current program?
  8. Factors for Success - Generally, what do you see as the key factors to the achievement of a strong values and ethics culture in your organization? What interventions would be most successful in counteracting any barriers to success? How would your current governance model need to change?

Thank you for participating in this study.

Appendix 2 – Focus group guide

Background on study

The Directorate of Liaison, Evaluation and Accountability (DLEA) in the Office of Public Services Values and Ethics has undertaken a study of practices in managing values and ethics (V&E) in the federal public service. The study is needed to provide departments and agencies, who are either just starting out or who are re-evaluating their own governance structures, with guidance on governance models and considerations to assist them in making informed decisions about what might work best within their organizations.

The study will: document various examples of values and ethics programs and their related responsibilities; elaborate several different governance models as potential practices; discuss the pros and cons of each; and make recommendations as appropriate.

Purpose of the focus group

A key part of the fact finding for the study is the conduct of one focus group with selected operational managers. The goal of the focus group is to:

  1. understand how the values and ethics program or model of the department works within their organization; and
  2. obtain viewpoints on what works best in managing and achieving effective values and ethics.

The focus group will last no more than two hours and involve anywhere from 6-10 participants.

Discussion guide

Introduction (5 minutes)

  • Facilitator will explain the purpose of the session as shown above.
  • Your feedback is very important and we are asking for your help in guiding research in the public service on appropriate models for values and ethics governance
  • Approach to session:
    • Purpose
    • Confidentiality
    • No right and wrong, opinions, etc.

Background (10 minutes)

  • Introductions: name, position, years of service, responsibilities with respect to values and ethics (if any), size of organization (budget and personnel) (Note: sign-up sheet in tabular format will be passed around).
  • What has been your involvement with the V&E program of the department? (Probe for: advice, training, training of staff, policy/rules, etc.)

Governance of values and ethics (1 hour and 15 minutes)

  • What outcomes should a V&E program attempt to achieve?
  • What support do you need from the values and ethics office in your organization compared to what you currently receive?

Embedding values and ethics in day-to-day practice (45 minutes)

  • What are the strengths of your values and ethics program in ensuring good values and ethics practice? (Prompt for the list below):
    • A secure disclosure
    • Confidentiality
    • Impartiality
    • Harassment issues identification/problem resolution
    • Respect and application of the Code
    • Staff awareness
  • What do you need to do to improve it further for the future?
  • What is the key competency you need to develop in values and ethics as an operational manager? What is the best way in which you can develop this competency?
  • What are the best methods or tools to communicate values and ethics information to employees?
  • What are you final thoughts…If there is one thing that has to be done critical to the success of the program, what would it be?

Thank you for participating in this focus group.


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