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Integrity Commissioner

Integrity Commissioner (By-law No. 2021-7)

Under the Municipal Act, 2001 (the Act), municipalities have authority to appoint various statutory officers to carry out certain functions as described in the legislation. At the City of Ottawa, the Integrity Commissioner (established further to Council’s approval in July 2012) is one of three statutory officers that report directly to City Council, along with the City Manager and Auditor General. The Statutory Officer Recruitment, Appointment and Contract Administration Policy and Procedures are used for recruiting, appointing and administering the contracts for these positions.

Pursuant to Subsection 223.3(1) of the Act, the Integrity Commissioner “reports to council and is responsible for performing in an independent manner the functions assigned by the municipality with respect to any or all of the following:

  1. The application of the code of conduct for members of council and the code of conduct for members of local boards.
  2. The application of any procedures, rules and policies of the municipality and local boards governing the ethical behaviour of members of council and of local boards.
  3. The application of sections 5, 5.1 and 5.2 of the Municipal Conflict of Interest Act to members of council and of local boards.
  4. Requests from members of council and of local boards for advice respecting their obligations under the code of conduct applicable to the member.
  5. Requests from members of council and of local boards for advice respecting their obligations under a procedure, rule or policy of the municipality or of the local board, as the case may be, governing the ethical behaviour of members.
  6. Requests from members of council and of local boards for advice respecting their obligations under the Municipal Conflict of Interest Act.
  7. The provision of educational information to members of council, members of local boards, the municipality and the public about the municipality’s codes of conduct for members of council and members of local boards and about the Municipal Conflict of Interest Act. 2017, c. 10, Sched. 1, s. 19 (1).”

This same subsection authorizes a municipality to appoint the Integrity Commissioner. Subsection 223.3(5) of the Act provides that the Integrity Commissioner “is not required to be a municipal employee.”

The Integrity Commissioner By-law [No. 2021-7] establishes this position and the duties of the Integrity Commissioner, including its statutory powers.

Role of the Integrity Commissioner

The Integrity Commissioner is an independent and impartial officer that reports directly to City Council and whose powers and duties are set out in the Municipal Act, 2001.

The City’s Integrity Commissioner is responsible for:

  • Providing advice to Members of Council and members of local boards respecting their obligations under their respective codes of conduct, the Municipal Conflict of Interest Act (MCIA) or other related policies;
  • Offering education and training to Members of Council, members of local boards, the City administration and the public about the codes of conduct and the MCIA;
  • Resolving complaints related to a potential breach of a code of conduct or the MCIA, either through informal resolution or a formal investigation;
  • Administering the City’s Lobbyist Registry including ensuring compliance with the Lobbyist Registry By-law and the Lobbyist Code of Conduct, investigating complaints, and imposing sanctions, as necessary; and
  • Reviewing the appropriateness of meetings of City Council, a local board or committee that are closed to the public.

Rulings and periodic reports by the Integrity Commissioner are posted on ottawa.ca.

The Commissioner also produces an annual report summarizing complaints, investigations and advice and makes recommendations for any improvements to the accountability process.

City Council approved the establishment of an Integrity Commissioner in July 2012 as part of the City’s Accountability Framework, which contains key elements of governance renewal intended to make municipal government more transparent and accountable.

Integrity Commissioner's biography

Robert Marleau, B.A., D.U.

Robert Marleau has 32 years of parliamentary service, 13 of which were spent as Clerk of the House of Commons (DM 2 equivalent). He left a rich legacy of achievement, including the authoritative procedural manual House of Commons Procedure and Practice, now in use in most Canadian legislatures.

On his retirement in 2001 he was made an honorary officer of the House of Commons by unanimous resolution of the House, and received an honorary doctorate degree from the University of Ottawa, his alma mater.

During his career at the House of Commons he occupied such positions as Deputy Secretary General for Interparliamentary Relations, Principal Clerk of the Committees Branch, Clerk Assistant, Clerk of the House and Special Advisor to the Speaker of the House. As Clerk of the House he was secretary to the Board of Internal Economy (BOIE).

His international assignments included serving as President of the parliamentary management committee for parliamentary co-operation with Russia and involvement with parliamentary co-operation with African, Caribbean and other Commonwealth countries. He has attended many Commonwealth, European and Francophonie international conferences. He also participated in missions to Hong Kong and Cuba.

He is a lifetime member of the Commonwealth Society of Clerks at the Table, an honorary member of the Association of Canadian Clerks at the Table and an honorary member of the Association of Former Parliamentarians.

In June 2003, he was appointed by the Governor in Council for a six-month term as Interim Privacy Commissioner of Canada with a mandate to restore credibility and sound management practices to the Privacy Office following the resignation of the former Commissioner. In December 2003, he returned to retirement and his parliamentary consulting practice with clients in Canadian, Caribbean and African legislatures, as well as municipal councils in Canada.

In January 2007, by unanimous resolution of the Senate and of the House of Commons, he was appointed Information Commissioner of Canada. After serving for two years and renewing and re-engineering the OIC and presenting a legislative review to Parliament, he returned to retirement in 2009.

He has appeared several times before House of Commons and Senate committees as an expert witness. He also has worked with McLaughlin Associates (CEO TV) as an associate in training programs for witnesses appearing before parliamentary committees.

He was a member of the panel of external senior advisors for the Auditor General's Office and has completed several assignments for that office. He was also a member of the panel of external advisors for the Public Service Commission of Canada

As part of his consulting practice, he has completed several assignments under contract for government departments and agencies (PCO, Treasury Board, PWGSC etc.)

He has also done work in Namibia, Trinidad and Tobago, Turks and Caicos and the Bahamas for the Commonwealth Parliamentary Association

He is a recognized expert in parliamentary practice and procedure and has proven management and strategic planning skills.

Security clearance: Top Secret

Honours:

  • Doctorate Honoris Causa, University of Ottawa
  • Honourary Table Officer of the House of Commons
  • Queen Elizabeth II Golden Jubilee Medal
  • Canada 125 Medal
  • Knight, Sovereign Military Order of Malta
  • Commander, Ordre de la Pléiade et de la Francophonie
  • Officer, Ordre de la Pléiade et de la Francophonie

Married to Ann, with two sons and four grandchildren

To contact the Integrity Commissioner, e-mail integrity@ottawa.ca.

How to request an investigation

Anyone who identifies or witnesses behaviour or an activity that they believe to be in violation of a Code of Conduct may pursue the matter either through the informal or formal complaint procedures. 

The Code of Conduct for Members of Council applies to Members of Council and citizen members of the Transit Commission (when acting in their official capacity).

All complaints received are handled in accordance with the Complaint Protocol.

Informal Complaint Procedure

Individuals are encouraged to use the informal complaint procedure in an effort to address behaviour or activity that they believe to be in violation of the Code of Conduct.

The informal procedure involves:

  1. Advising the Member that the behaviour or activity appears to contravene the Code of Conduct
  2. Encouraging the Member to acknowledge and agree to stop the prohibited behaviour or activity and to avoid future occurrences of the prohibited behaviour or activity
  3. Documenting the incidents including dates, times, locations, other persons present, and any other relevant information
  4. Requesting the Integrity Commissioner to assist in informal discussion of the alleged complaint with the Member in an attempt to resolve the issue
  5. If applicable, confirming to the member your satisfaction with the response of the Member; or, if applicable, advising the Member of your dissatisfaction with the response

Formal Complaint Procedure

Individuals who wish to make a formal complaint must do so by filling in the Request for Investigation Form along with a signed affidavit.

Complaints must include information to support the allegation(s) made against a Member including dates, locations, other persons present and all other relevant information.

Complaints must be signed by an identifiable individual. No anonymous complaints will be considered.

Code of Conduct for Members of Council - Request for Investigation Form

Code of Conduct for Citizen Members of the Built Heritage Sub-Committee - Request for Investigation Form

Code of Conduct for Members of Local Boards - Request for Investigation Form