Disclosure of wrongdoing

EDC’s senior vice-president and chief internal auditor has been designated as the senior officer of internal disclosure (SOID), which enhances the Corporation’s transparency and accountability.

The SOID receives and reviews questions from stakeholders which may include fielding internal inquiries with respect to EDC’s Code of Conduct, the Values and Ethics Code for the Public Sector, the Public Servants Disclosure Protection Act, and EDC’s Wrongdoings Policy.

EDC employees are required to abide by the public-sector-wide Values and Ethics Code introduced on April 2, 2012. The Values and Ethics Code for the Public Sector sets out high level values and principles which are consistent with EDC’s own Code of Conduct. EDC’s SOID is a resource for members of the public who may have reason to believe an EDC employee is not complying with the Public Sector Code.

Guidelines for submitting a disclosure of wrongdoing to the SOID

Who can submit a disclosure of wrongdoing

Members of the public who have reason to believe that an EDC employee has not acted in accordance with the Public Sector Code can bring the matter to the SOID, who has been designated for hearing such concerns. If an issue is being raised on behalf of another party, that group should be identified and evidence of authority to represent that group provided. Anonymous submissions are not accepted, however material can be submitted confidentially to support a question or issue. 

What to include

The submission must be in writing, or submitted electronically via our Request for Review Form. While it does not need to follow a specific format, it does help to speed up the process if we receive the following details:

• Your name, address and other contact information such as phone and fax numbers, cell phone, email address.
• If you are representing a complainant, please provide contact information for yourself and the group/person you are representing.
• Background information on your complaint, including the names of any people you may have dealt with in an attempt to resolve the issue or raise your concerns.
• A clear statement outlining your opinion of the social, business or environmental impact of the problem.
• Your opinion on the desired result or outcome of an investigation so that we have a clear understanding of what you expect from the process.
• What has been done to solve the problem, including any previous contact with EDC.

Acknowledging receipt

You will usually receive acknowledgement within five business days.

Appraising a submission

The SOID will determine if a submission falls within the mandate. If the submission is accepted, it is registered in a database and given an identifying number to help ensure it is dealt with in a timely fashion. You will be notified when a submission has been accepted and given an estimate of how long it will take to review. If the submission does not fall within our mandate, you will receive a response outlining the reasons.

Preliminary assessment

A preliminary assessment is done to evaluate the submission and determine how it should be handled. This concludes with a decision of whether to proceed and, if so, an outline of the course of action proposed.

Resolution

Depending on the nature of the submission and the SOID’s assessment, one or more of the following three options will be recommended to resolve the issue:

• Promotion of dialogue.
• Audit.
• Corrective measures.

Conclusion

The SOID can conclude or close a submitted disclosure of wrongdoing at any time if a satisfactory resolution has been reached or when it is felt further investigation or problem-solving techniques will not be useful or productive. You will be advised in writing if this decision is made. When this happens, the officer has two courses of action available:

• Report to the President and CEO that attempts have not been successful and that no further action is possible
• Report to the President and CEO with recommendations about future action, which could address any concerns raised

Monitoring and follow-up

As part of the resolution, the SOID will include a process for follow-up monitoring and review. 

Confidentiality and disclosure

The SOID’s role works in such a way that the confidentiality of information needed to run an effective process is given priority over the actual product or outcome. The idea is that an open and flexible attitude toward problem-solving is more likely if resolution processes are conducted with a reasonable level of confidentiality. Therefore, communication with parties during the course of the dispute resolution process will be regarded as privileged. Similar constraints will apply when confidential business information is received during investigations.

Treasury Board of Canada Values and Ethics

Values and Ethics Code for the Public Sector