Integrity Commissioner

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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

Karen Shepherd

Karen Shepherd has more than 30 years of federal Public Service, more than half of which was spent in the ethics field.

As a bilingual executive, she built a reputation for outstanding public sector leadership and contributed to the effective management of the Public Service by improving ethics and transparency so that Canadians may have confidence in the integrity of public decisions.

In June 2009, she was appointed as Canada’s first Lobbying Commissioner. She established a fully independent Office while ensuring a professional and respectful working relationship with Parliamentarians, lobbyists, colleagues and other stakeholder groups. She successfully managed a two-year national consultation process that resulted in a stronger federal Lobbyists Code of Conduct.

During her tenure, she was instrumental in creating a Canada-wide forum for inter-jurisdictional discussion amongst provincial and municipal lobbying regulators through the Lobbying Commissioners and Registrars Network. Such a forum is fundamental supporting a culture of compliance in those jurisdictions. Additionally, building such a network of professional regulators ensured that a learning culture was established to support better decision-making.

She was an advocate for international collaboration on ethics and lobbying with likeminded countries. She was an active member with the Council on Government Ethics and Law (COGEL). As Commissioner of Lobbying, she created strong bilateral ties with several countries including the United States, Chile and Peru.

Given her experience in ethics, she was asked to join the Senior ranks at Health Canada as Executive Advisor to the Deputy Minister and provided advice on engagement and transparency issues on key files such as the Opioid Crisis. Before retiring in 2020, she assumed the role of Ombudsman for Health Canada and the Public Health Agency and took pride in creating a safe space for employees and strengthening relationships with key partners including bargaining agents.

Over the span of her career, she worked in several departments and gained experience in policy, operational and social responsibility units. She provided strategic, confidential and fearless advice to many including lobbyists, elected and senior public officials, and built strong and collaborative partnerships both inside and outside of Government. In 2010, she received the Bissett Alumni Award from Carleton University for Distinctive Contributions to the Public Sector.

She holds a Master’s Degree in Public Administration from Carleton University and a Baccalaureate of Arts (Economics and Administration) from Concordia University.

She has been happily married to her husband, Robert, for more than 30 years.

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