Conflict of Interest
A conflict of interest (COI) arises from an activity or situation that places a Department of National Defence (DND) employee or a Canadian Armed Forces (CAF) member in a real, potential or apparent conflict between their private interests and their official duties and responsibilities, or even between those of the organization and that of the public interest.
The avoidance of COI is one of the primary means by which DND employees and CAF members maintain public confidence in the impartiality and objectivity of the Public Service and the CAF.
Information: Are you aware of a serious breach of conduct under the DND and CF Code of Values and Ethics or the Code of Service Discipline?
If so, please contact our Internal Disclosure Office to submit a disclosure of wrongdoing (more commonly known as 'whistleblowing').
Not sure what a serious breach of conduct is? You can contact our Internal Disclosure Office for advice.
Frequently Asked Questions
Notes from the Director-Defence Ethics Programme (DDEP):
- The answers in this section are general in nature and are meant to be a guide for the reader. It is important to bear in mind that each case must be analyzed on the basis of the details that are relevant to it and that may influence the decision.
- For more information, refer to the relevant orders and directives or contact the COI section of the Defence Ethics Programme (DEP) at COIDEP-CIPED@forces.gc.ca or 1-855-447-1112.
Select a question from the list below to read the answer.
- What are the policies governing COI in the DND/CAF?
- What is a COI?
- Is an apparent COI in itself a reason for having some restrictions imposed?
- When and to whom am I required to submit a confidential report?
- Should I submit a new confidential report if, after having ceased my previously approved outside activity, I resume this activity?
- What is a delegated authority?
- Are Reservists subject to these measures?
- What general conditions should I meet when I engage in an activity or employment outside of my official duties?
- As a full time DND employee or CAF member, am I allowed to serve as a volunteer firefighter for my municipality?
- Can I enter into a contract for services with the government?
- Can I teach a course at the Royal Military College (RMC) for pay?
- Can I accept promotional items offered by companies that do business with DND or the CAF?
- Can I accept courtesy tickets offered by a company that does business or would like to do business with DND or the CAF?
- During certain courtesy visits abroad, my hosts have given me a gift of considerable value. Am I allowed to keep it?
- How do I dispose of a gift of considerable value that I cannot keep for private use?
- How do I dispose of an asset through the Crown Assets Disposal Corporation?
- Can I accept an invitation to an activity, a golf tournament for example, organized by a DND supplier?
- Are we permitted to organize an internal activity, such as a golf tournament, to recognize the good work performed by our staff and also to foster team spirit within our unit?
- Can I solicit gifts or other donations from businesses for events organized by my division or branch?
- What is meant by 'non-exempt assets'?
- When and how am I required to report assets and liabilities?
1. What are the policies governing COI in the DND/CF?
DAOD 7021-1 Conflict of Interest, DAOD 7021-2 Post-Employment, DAOD 7021-3 Acceptance of Gifts, Hospitality and Other Benefits and DAOD 7021-4 Solicitations, Sponsorships and Donations are the orders and directives that govern conflict of interest. These apply to employees of DND and members of the Regular Force and CAF Reserve.
In addition, civilian employees are subject to the provisions of the Values and Ethics Code for the Public Service.
A COI arises from an activity or situation in which DND employees or CAF members' private interests inappropriately influence or give the impression of inappropriately influencing their performance or decisions while carrying out their official duties. A COI may be real, potential or apparent.
Yes. The appearance alone of a COI may lead to restrictions of certain activities.
With respect to COI, the courts recognize that public institutions are subject to higher ethical and conflict of interest standards. Tolerating apparent conflicts of interest between the private interests of public servants and their obligations to the general public has a negative impact on the perception of integrity and impartiality of the public service. Therefore, the conduct of public officials and CAF members shall bear the closest public scrutiny; simply acting within the law is not sufficient.
You are required to submit a Confidential Report (DND Form 2839E) to the COI Section, in any set of circumstances where you own a non exempt asset, practice of an outside activity or employment, or participate in political activities, regardless of your functions in the political organization and or its jurisdiction (band council, school board, municipal government, provincial or territorial legislatures or federal politics). This includes participation on election or re-election committees or being a volunteer for a political formation.
So long as there is no change to your outside activity or official duties, you are not required to re submit a report for an activity that was previously reported and for which no COI was identified.
In certain cases related to contracting with the government, such as when occupying two positions paid out of the consolidated revenues fund, you are required to obtain permission from a delegated authority prior to contracting. This delegated authority will be a director at NDHQ or a base commanding officer, in accordance with DCCS Directive 6004-12, Dual Remuneration.
For CAF members, in situations involving directorships in private-sector corporations, the delegated authority will be the Assistant Deputy Minister (Review Services) at NDHQ (QR&O 19.43 (1)(c)).
Reservists in Class A are only required to submit a DND Form 2839E if they work in the defence industry and they are of a rank that could lead to a perception of preferential treatment.
Outside activities or employment
The outside activity or employment must not interfere with the performance of your duties. You must engage in your outside activity or employment outside of your working hours at DND or the CAF. Moreover, you may not benefit from information obtained in the course of your duties and which is not accessible to the general public. Lastly, you may not use DND or CAF facilities, equipment or material in your outside activity or employment.
Under QR&O 19.42, if you are a CAF member you must obtain written authorization from your commanding officer before committing to an outside activity or employment.
You may serve as a volunteer firefighter, so long as you engage in your activities outside your working hours at DND or the CAF, unless special arrangements have been made between the municipality and your unit and so long as you do not use DND or CAF premises, equipment or material. The outside activity must not in any way undermine the exercise of your official responsibilities and duties, and you are not permitted to respond to a fire alarm in your military uniform.
If you are a CAF member you must obtain authorization from your commanding officer before becoming a volunteer firefighter.
CAF members must submit a Confidential Report (DND Form 2839E) as well as the DND 4086 - Statement of Understanding for Civil Employment or Volunteering, acknowledging the consequences and risks for any resulting injuries relative to DAOD 5023-1 Minimum Operational Standards Related to Universality of Service.
Service contracts with the government
Yes, if you are a DND civilian employee or CAF member you may enter into service contracts with the government, including a DND/CAF agency, through regular contracting channels. However, certain measures must be taken before a contract can be awarded.
If you are a civilian employee you must inform your supervisor in writing and obtain authorization from the Deputy Minister (DM) or the delegated authority of your work unit (refer to DCCS Directive 6004-12, Dual Remuneration). You must then submit a Confidential Report (DND Form 2839E) to the COI Section.
The service contract activities must not be related to your official duties and must not interfere with the performance of your duties.
Teaching contracts with DND and the CF
You are permitted to accept a teaching contract from RMC provided you teach outside your usual working hours and do not use DND or CAF premises, equipment or material in preparing your courses other than those provided specifically for course purposes. You are required to perform your official duties and arrange your private affairs in a manner that preserves public confidence and trust in the integrity, objectivity and impartiality of DND and the CAF.
Acceptance of promotional items
As a DND employee or CAF member you may accept gifts, hospitality and other benefits if they are of minimal value (inexpensive promotional objects, light meals, souvenirs that cannot be converted into cash).
If these goods and services are not of minimal value, you must obtain authorization from an approval authority, i.e., your Level 1 Advisor or, if you work outside the National Capital Region (NCR), your Level 2 Advisor. Level 1 Advisors must obtain authorization from the DM, for civilian staff, or the Chief of the Defence Staff (CDS), for CAF members.
Acceptance of tickets to cultural, recreational or sports activities
Generally speaking, no, because as a rule, such tickets are fairly expensive. You must avoid being placed or appearing to be placed under an obligation to any person or organization that might profit from special consideration. That being said, each case should be reviewed individually; you are advised to consult the COI Section at COIDEP-CIPED@forces.gc.ca before accepting tickets.
Acceptance of gifts
In circumstances where it would contravene diplomatic protocol or the protocol of a foreign country, you may not be able to refuse a gift. Not having obtained prior written authorization to accept the gift, you must report it to your commanding officer or supervisor as soon as possible, preferably in writing. They will submit it to the appropriate approval authority, either the DM, the CDS, your Level 1 Advisor or, if you live outside the NCR, your Level 2 Advisor.
Your Level 1 Advisor or, if you work outside the NCR, your Level 2 Advisor will decide what measures to take as there are several options. For example, the object could be displayed in a showcase or placed in common areas within your organization (conference room or unit offices). The best option, however, is to dispose of it through the Crown Assets Disposal Corporation.
The unit in charge of managing the disposal of crown assets is CFSU Ottawa - Return and Disposal/Key Materiel/Received and Delivered (RD KM RD). The unit can be reached at 613-991-6880 or 613-991-0404. Assets are generally sold at regularly scheduled auctions by Public Works and Government Services Canada (PWGSC).
Acceptance of invitations to golf tournaments or events
Generally speaking, no, because these activities are usually fairly expensive. You must avoid being placed or appearing to be placed under an obligation to any person or organization that might profit from special consideration. That being said, cases should be reviewed on an individual basis; you are advised to consult the COI Section at COIDEP-CIPED@forces.gc.ca before accepting such invitations.
In the case of internal employee activities (barbecue, curling, golf, etc.) for which no gifts are solicited from the private sector, it is up to management to decide whether or not to hold an activity.
Except where otherwise stipulated in DAOD 7021-4 Solicitations, Sponsorships and Donations, soliciting gifts, hospitality or other benefits from persons, groups or organizations in the private sector is strictly prohibited.
Can I solicit gifts or other donations from businesses for charity campaigns organized at the office?
Other than for the Government of Canada Workplace Charitable Campaign, the Royal Canadian Legion Poppy Fund, the Red Cross Blood Drives and the Military Police Fund for Blind Children, you are required to obtain prior written authorization from the DM or the CDS to solicit gifts or contributions from outside organizations or persons. Obtaining the required authorization in no way reduces your obligation to avoid real, potential or apparent COI situations. The DM or the CDS Staff may require that activities be reduced, modified or abandoned if a risk of COI is identified.
However, this does not preclude provisions of services at any time when the conditions set in the policy manual B-GS-055-000/AG-001, Provisions of Service are respected.
"Non-exempt assets" are all assets and interests other than those of a noncommercial nature intended for the private use of DND employees, CAF members and their families. These constitute publicly traded securities, foreign government securities, self-administered RRSPs, self-administered RESPs, interests in companies and businesses, real property that is not for your private use or your family members, as well as liabilities in respect of these assets. A non-exhaustive list of nonexempt assets is found in DND Form 2839E, COI under "Assets, Liabilities and Trusts".
You are required to report your assets and liabilities in a Confidential Report (DND Form 2839E) if they may give rise to a real, potential or apparent COI affecting your official duties within DND or the CAF.
Your report must be submitted to COI Section at COIDEP-CIPED@forces.gc.ca.
Conflict of Interest DAODs and Guidelines
- Conflict of Interest and Post-Employment DAOD 7021-0
- Conflict of Interest DAOD 7021-1
- Acceptance of Gifts, Hospitality and other Benefits DAOD 7021-3
- Sponsorships and Donations DAOD 7021-4
- Archived—Interim Partnering Guidelines (PDF 432kb)
- Archived—Obligation to Submit Confidential Report Before Engaging in Defence-Related Outside Employment (PDF 131kb)
- Archived—Acceptance of Invitations to Golf Tournaments
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