Disclosure Reports of Wrongdoing - 2017-2018
In December 2017, a number of disclosures regarding the conduct of an EDC employee were made to the Senior Officer for Internal Disclosure under the Public Servants Disclosure Protection Act (PSDPA), EDC’s Chief Compliance & Ethics Officer.
Descriptions and findings
It was alleged that an employee approved invoices for questionable expenses submitted by a vendor while a member of their family was simultaneously seeking employment with that vendor. (An offer of employment was subsequently accepted.) The employee did not disclose the conflict situation and did not recuse him-or-herself from approving expenses or from participating in selection processes involving that vendor.
The investigation concluded that the employee was in conflict of interest and seriously breached EDC’s Code of Conduct, and as such that these actions constituted a wrongdoing as defined by the PSDPA.
In addition, on multiple occasions, the same employee sent emails containing confidential EDC information to a member of his-or-her family at the family member’s workplace.
The investigation into these actions found the employee contravened federal and-or provincial law(s), as well as committed gross mismanagement. The employee was also found to be in serious breach of EDC’s Code of Conduct. The investigation concluded that these actions also constituted a wrongdoing as defined by the PSDPA.
Recommendations and Corrective Measures
The Senior Officer for Internal Disclosures informed the President and Chief Executive Officer of the findings of the investigation, and all recommendations have been accepted and are being implemented. It was recommended that:
· EDC conduct an audit of the contracts with the vendor and review the amounts invoiced to EDC.
· EDC take steps to remind employees of their duties to report potential conflicts of interest; their obligations regarding confidentiality; and the potential impact of disclosure of confidential information to third parties.
As well, after careful consideration of all factors, the decision was made to terminate the employment of the employee.
EDC conducts annual awareness training regarding its Code of Conduct. This is a mandatory program that all employees must complete. In addition, once a year all employees are required to confirm their understanding of and adherence to EDC’s Code of Conduct. To ensure even greater employee awareness, the President sent a corporate-wide email informing all employees of the findings of this investigation (as disclosed above), and reiterating the imperative of ethical behaviour as a foundational principle of the organization.
Independent of this case, earlier in 2017, EDC began a complete review and redrafting of its employee Code of Conduct. The revised code, scheduled for release at the end of Q1 2018, provides information in clearer and accessible language, includes definitions and examples, as well as links to resources, detailed policies and guidelines, along with contact information for additional support and consultation.
In 2018 EDC is also launching an internal Compliance and Ethics website, giving employees a centralized resource hub for all code of conduct and ethics-related materials and information.