Disclosure of wrongdoing
EDC’s senior vice-president and chief internal auditor has been designated as the senior officer of internal disclosure (SOID), which encourages a speak-up culture and 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, and the Public Servants Disclosure Protection Act.
EDC employees are required to abide by the public-sector-wide Values and Ethics Code. 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.
How to submit a disclosure of wrongdoing
Email your request to SOID@edc.ca either by attaching a completed Request for Review Form or by including disclosure details in the email itself. While there is no set format, providing the following information will help us process your request more efficiently:
- 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 of receipt 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 of the outcome of any review and/or investigation into the disclosure and on the status of actions taken on the disclosure, as appropriate.
Preliminary assessment
A preliminary assessment is done to evaluate the submission and determine how it should be handled.
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 submission 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. When this happens, the SOID 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.
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