The Compliance Officer role was created to enhance our transparency and accountability regarding the public disclosure of information, internal disclosure of wrongdoing, environmental reviews, human rights practices and business ethics. Much like an ombudsman, the Officer operates independently from management, receiving and reviewing complaints from stakeholders and fielding inquiries about our Corporate Social Responsibility (CSR) policies and initiatives.
The Officer also acts as an independent broker between parties, to find mutually satisfactory resolutions. In an advisory role, the Officer helps identify and correct potential problems while maintaining a balance of impartiality and fairness. Consequently, the Officer closely monitors corporate activities and policy initiatives so that issues can be identified and viable alternatives recommended.
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 organizational Code of Conduct and Code of Business Ethics. Monica Ryan, EDC’s Compliance Officer under the Disclosure of Wrongdoing Policy, has been designated as the contact person for members of the public who may have reason to believe an EDC employee is not complying with the new public sector code.
Monica Ryan, Vice President Internal Audit & Compliance Officer
Ms. Ryan has more than 20 years experience, the last 10 of which have been in various leadership roles within internal audit in the technology sector. Most recently, Ms. Ryan was Vice President Internal Audit at Cognos Inc. Before joining Cognos, Ms. Ryan was with Alcatel-Lucent where she held the positions of Global Audits Director based in Paris, France and Regional Audit Director for the Americas based in Dallas, Texas. Ms. Ryan began her career with PriceWaterhouseCoopers where she was a Principal for the Business Risk & Control practice within the Ottawa office. Ms. Ryan has a Bachelor of Commerce (Honours) from the University of Ottawa. She is also a Chartered Accountant and Certified Public Accountant.
Guidelines for submitting a complaint
Who can File a Complaint
Any individual, group, community, entity or other party affected or likely to be affected by EDC’s corporate social responsibility policies and initiatives can submit a complaint. If a complaint is being made on behalf of another party, that group should be identified and evidence of authority to represent that group provided. Anonymous complaints are not accepted, however, material can be submitted confidentially to support a complaint. This information will not be released without the consent of the party who provided the information.
What to Include in a Complaint
The complaint 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.
You will receive acknowledgement usually within five business days.
Appraising a Complaint
The Compliance Officer will determine if a complaint falls within the mandate. Complaints that are accepted are registered in a database and given an identifying number to help ensure they are dealt with in a timely fashion. You will be notified immediately when a complaint has been accepted and given an estimate of how long it will take to review. If it is decided to reject the complaint, you will receive a letter outlining the reasons.
A preliminary assessment is done to evaluate the complaint 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 of a Complaint
Depending on the nature of the complaint and the Compliance Officer’s assessment, one of three options will be recommended to resolve the complaint as follows:
- Promotion of dialogue
- Dispute resolution or
- Compliance audit.
The Compliance Officer can conclude or close a complaint 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 Compliance Officer has two courses of action available:
- Report to the Board of Directors that attempts have not been successful and that no further action is possible.
- Report to the Board of Directors and make recommendations about future action, which could address concerns in the complaint.
Monitoring and Follow-up
As part of the resolution, the Compliance Officer will include a process for follow up monitoring and review. The Compliance Officer can ask EDC to help ensure monitoring and follow up is done.
Confidentiality and Disclosure
The ombudsman-like 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 dispute resolution process will be regarded as privileged. Similar constraints will apply when confidential business information is received during investigations.
How to submit a complaint
English and French complaints can be emailed to firstname.lastname@example.org
You can also fill in an electronic Request for Review Form.
Turning the Corner of Trade: Annual Report 2013
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