Values and Ethics Code for Agriculture and Agri-Food Canada

Introduction

Agriculture and Agri-Food Canada (AAFC) provides information, research and technology, and policies and programs to achieve security of the food system, health of the environment and innovation for growth. AAFC, along with its portfolio partners, reports to Parliament and Canadians through the Minister of Agriculture and Agri-Food.

At AAFC, we are committed to fulfilling this mandate in all our professional activities by fostering an environment that values diversity, equity, inclusion, responsible leadership, accessibility, accountability and respect for all employees, ensuring a workplace free from discrimination and bias. As public servants, we take pride in embodying the values and behaviours of the Canadian federal public sector. The Values and Ethics Code for AAFC (AAFC’s Code) sets out these values. It also includes more specific measures related to conflict of interest (COI) and post-employment, which serve to uphold our public sector values. Avoiding and preventing COI is one of the primary ways in which a public servant maintains public confidence in the impartiality and objectivity of the public service.

Having a clear set of values is essential in shaping an organization’s culture. Acting in accordance with the values and behaviours set out in AAFC’s Code solidifies the foundation of a fair, equitable, accessible and inclusive work environment and sustains the trust and confidence of the public in ourselves, our leaders, our organization and the public service. When you read the Code, you will understand what is expected of you as an AAFC employee.

Part 1: Context and application

1.1 Context

In accordance with section 5 of the Public Servants Disclosure Protection Act (PSDPA), the Treasury Board Secretariat (TBS) established the Values and Ethics Code for the Public Sector (VECPS) in 2011. Section 6 of the PSDPA requires that all departments develop their own codes to complement the broader VECPS.

AAFC introduced its first Values and Ethics Code in 2012. This updated Code reflects over a decade of experience and learning. It incorporates modernized language that is inclusive and respectful, ensuring all employees feel reflected in its content. The revision also incorporates best practices for civility in the workplace and ethical leadership, aligning AAFC’s work with evolving ethical standards related to science and technology, and includes ethical considerations when using artificial intelligence (AI). It also covers ethical risks and mitigating measures related to COI.

The AAFC Code may not address every situation. Where clarity is required, employees are expected to consult with their manager or with AAFC’s Values and Ethics Policy Centre (VEPC).

1.2 Application

The VECPS and related directives, policies and guides, including AAFC’s Code and TBS’s Directive on Conflict of Interest, form part of the terms and conditions of employment of all AAFC employees. Non-compliance may result in disciplinary measures, up to and including termination of employment. The term “employee” refers to indeterminate and term employees, executives, students, casual, seasonal and part-time workers and persons working by means of a secondment. Outside of regular working hours and while on leave, including leave without pay, employees continue to be subject to both codes and must continue to abide by them for the duration of their leave.

Although they are not public servants, individuals on incoming Interchange Canada assignments, honorary scientists, honorary research associates, research participants, volunteers and contractors are expected to respect the requirements of AAFC’s Code. Order-in-council appointees, such as deputy heads, are subject to the Conflict of Interest Act.

The AAFC Code also includes one-year post-employment COI provisions that apply to certain positions at AAFC that involve official duties that raise post-employment concerns, including all those classified as executive (EX) positions, those classified as EX minus 1, EX minus 2, and their equivalents.

Part 2: Values and ethics

2.1 Statement of values

These values are a compass to guide public servants in everything they do. They cannot be considered in isolation from each other as they will often overlap. AAFC’s Code is the principal source of guidance for employees in choosing their course of action. The values of this Code must be integrated in our decisions, actions, behaviours, policies, processes and systems throughout our daily business practices. Similarly, AAFC employees can expect to be treated in accordance with these values.

Respect for democracy

The system of Canadian parliamentary democracy and its institutions are fundamental to serving the public interest. Public servants recognize that elected officials are accountable to Parliament, and to the Canadian people, and that a non-partisan public sector is essential to our democratic system.

Respect for people

Treating all people with respect, dignity and fairness is fundamental to our relationship with the Canadian public and contributes to an accessible, physically and psychologically safe and healthy work environment that promotes equity, inclusion, engagement, openness and transparency. Recognizing and valuing the diversity of ideas, perspectives, lived experiences and people – including gender identity, sexual orientation, ancestry, origins and ability – is fundamental to our work. Fostering an accessible and healthy environment of inclusion, equity and respect for all individuals is the source of our creativity and innovation.

Integrity

Integrity is the cornerstone of good governance and democracy. By upholding the highest ethical standards, public servants conserve and enhance public confidence in the honesty, fairness and impartiality of the federal public sector.

Stewardship

Federal public servants are entrusted to use and care for public resources responsibly, for both the short term and long term.

Excellence

Excellence in the design and delivery of public sector policy, programs and services is beneficial to every aspect of Canadian public life. Engagement, collaboration, effective teamwork, accountability and professional development are all essential to a high-performing organization.

2.1.1 Expected behaviours

AAFC employees are expected to conduct themselves in accordance with the values of the department and the public sector and the following expected behaviours:

Respect for democracy

AAFC employees shall uphold the Canadian parliamentary democracy and its institutions by

  • respecting the rule of law and carrying out their duties in accordance with legislation, policies and directives in a non-partisan, equitable and impartial manner
  • loyally carrying out the lawful decisions of their leaders and supporting ministers in their accountability to Parliament and Canadians
  • providing decision-makers with all the information, analysis and advice they need, always striving to be open, accessible, candid and impartial
  • adhering to the responsible and ethical use of public platforms, such as social media

Respect for people

AAFC employees shall respect human dignity and the value of every person by

  • treating every person, including those from marginalized and underrepresented communities, with respect, equity, fairness and dignity — accepting and valuing diverse identities and experiences
  • valuing diversity, equity and inclusion and the benefit of combining the unique views and qualities inherent in a diverse workforce
  • helping to create and maintain a physical and psychologically safe, healthy, accessible and inclusive workplace where employees – regardless of race, gender identity, sexual orientation, or other aspects of identity – feel welcomed and empowered to express their perspectives, voice concerns without fear of reprisal, and actively contribute to a culture that is free from harassment and discrimination
  • working together in a spirit of inclusion, openness, honesty and transparency that values diverse perspectives and abilities and encourages engagement, collaboration and respectful communication
  • promoting accessibility and inclusion to ensure that decisions, policies and programs do not disproportionately impact any one group, particularly those historically marginalized, while also fostering equitable opportunities for career progression and advancement

Integrity

AAFC employees shall serve the public interest by

  • acting at all times with integrity and in a manner that will bear the closest public scrutiny, an obligation that may not be fully satisfied by simply acting within the law
  • never using their official roles to inappropriately obtain an advantage for themselves or to advantage or disadvantage others
  • taking all possible steps to prevent and resolve any real, apparent or potential conflicts of interest between their official responsibilities and their private affairs in favour of the public interest
  • upholding the integrity of scientific practices by ensuring that research is conducted ethically and that the decision to communicate and disseminate results is made in a way that is fair, reasonable, transparent and accountable
  • acting in such a way as to maintain their employer's trust

Stewardship

Public servants shall use resources responsibly by

  • effectively and efficiently using the public money, property and resources managed by them
  • considering the present and long-term effects that their actions have on people and the environment
  • acquiring, preserving and sharing knowledge and information as appropriate
  • adhering to the responsible and ethical use of artificial intelligence and other digital technologies

Excellence

Public servants shall demonstrate professional excellence by

  • providing fair, timely, efficient and effective services that respect Canada's official languages
  • continually improving the quality of policies, programs and services they provide
  • fostering a work environment that promotes diversity, inclusion, accessibility, teamwork, learning, innovation and physical and psychological health and safety
  • promoting a culture of ethical leadership, where decision-makers at all levels serve as role models for integrity, fairness, accountability and the inclusion of diverse perspectives
  • striving for diversity, equity and inclusion in leadership, ensuring that opportunities for career development and professional advancement are available to all employees, regardless of their race, background, ability or identity

2.1.2 AAFC’s commitment to reconciliation

At AAFC, reconciliation is a core value that guides our work within the public service, particularly in our relationships with Indigenous communities. As a federal department, we acknowledge the lasting impacts of colonial practices, policies and systemic barriers on First Nations, Inuit and Métis Peoples. We recognize that true reconciliation requires more than acknowledgement – it requires meaningful action and systemic change. This commitment involves re-examining our workplace culture, policies and practices to respect Indigenous knowledge, land stewardship and sustainable resource use, while also ensuring they are free from discrimination, reflect Indigenous rights and perspectives, and foster a welcoming and safe environment for Indigenous employees. By integrating traditional Indigenous wisdom with modern agricultural methods, we aim to support both environmental sustainability and community well-being.

AAFC is dedicated to expanding our understanding of Indigenous contributions to agriculture, food systems and the environment. This involves increasing Indigenous representation at all levels within the department, ensuring that Indigenous employees have equitable opportunities for career advancement, integrating Indigenous perspectives in decision-making, and building partnerships that enable communities to shape policies affecting their lands, food systems and livelihoods.

2.1.3 AAFC’s commitment to upholding ethical scientific practices

AAFC is dedicated to upholding the highest standards of ethical scientific practices and responsible research conduct. The department ensures integrity, transparency and accountability in all our research and scientific activities by adhering to rigorous ethical guidelines, such as tthe Science Ethics Policy Framework and the Science Integrity Policy. AAFC promotes integrity in data collection and analysis and fosters an environment of respect for diverse perspectives. The department works to advance knowledge and innovation in ways that maintain public trust, ethical responsibilities and scientific excellence.

2.1.4 AAFC’s commitment to the responsible and ethical use of AI

AAFC is committed to the responsible and ethical use of AI by prioritizing the protection of privacy, the prevention of bias, the promotion of inclusivity and continuous learning. AAFC employees must ensure that risks are assessed, managed and aligned with principles of administrative law such as transparency, accountability, legality and procedural fairness. Government of Canada guidelines must be followed when using AI, including

  • using only unclassified information
  • ensuring content is accurate, unbiased and compliant
  • using AI transparently, aligning with the highest ethical standards

2.1.5 AAFC’s commitment to ethical leadership

AAFC is committed to equipping leaders with the tools, resources and training necessary to support ethical leadership. The term leaders can refer to employees holding a position of authority and influence within the organization and is not limited to executives. It extends to management and to all employees who have the ability to influence and lead others.

Managers are expected to lead by example, cultivating a culture of integrity, respect and accountability in every action. Their leadership must support the well-being of all employees, inspire trust, foster collaboration and inclusivity, and uphold the highest standards of ethical conduct in all areas of their work.

2.1.6 Avenues for resolution

AAFC employees at all levels must resolve issues fairly and respectfully. When ethical issues arise, employees are encouraged to discuss and resolve these matters with their immediate supervisor. They can also seek advice and support from other resources within the department.

At AAFC, the following resources are available to employees:

  • Values and Ethics Policy Centre provides advice and guidance to employees and managers on values and ethics, conflict of interest and other ethical matters.
  • Informal Conflict Management Services provides AAFC employees with options to help prevent, manage and resolve workplace conflict.
  • Harassment and Violence in the Workplace Prevention Program helps employees and managers navigate services and processes to address harassment and workplace violence.
  • Labour Relations provides managers with interpretation and advice on collective agreements, updates on collective bargaining negotiations, and the prevention and resolution of harassment.
  • Office of the Ombuds provides employees with an independent, informal, confidential and impartial space to address workplace issues.
  • Science Ethics Committee provides advice on ethical topics related to science, reviews and investigates allegations of ethical misconduct in scientific practices and non-compliance with established ethical guidelines.
  • Human Research Ethics Committee examines all experimental protocols involving human participants, provides recommendations and grants approval for the studies.
  • AI Centre of Excellence establishes standards, guidelines, and procedures for the responsible and ethical use of AI and reviews and approves AI digital initiatives from an ethical perspective throughout the initiative’s lifecycle.
  • Office for Internal Disclosure provides a forum for all employees to report and disclose wrongdoing in the workplace and ensures that employees are treated fairly and with respect and are protected from reprisal.

As provided by sections 12 and 13 of the PSDPA, if employees have information that could indicate a serious breach of AAFC’s Code, they can bring the matter, in confidence and without fear of reprisal, to the attention of their immediate supervisor, the Senior Officer for Internal Disclosure at AAFC, or the Public Sector Integrity Commissioner.

Members of the public who have reason to believe that a public servant has not acted in accordance with the AAFC Code can bring the matter to the Senior Officer for Internal Disclosure, the Deputy Minister or the Public Sector Integrity Commissioner to disclose a serious breach of this Code.

2.1.7 Duties and obligations

Ministers

Ministers are responsible for preserving public trust and confidence in the integrity of public sector organizations and for upholding the tradition and practice of a professional non-partisan federal public sector. Furthermore, ministers play a critical role in supporting public servants' responsibility to provide professional and frank advice. 

Deputy Minister of AAFC

The Deputy Minister has specific responsibilities under the PSDPA, including establishing a code of conduct for AAFC and an overall responsibility for fostering a positive culture of values and ethics within the department. The Deputy Minister must ensure that employees are aware of their obligations under AAFC’s Code and that they can obtain appropriate advice within the department on ethical issues, including possible COI. The Deputy Minister must also ensure that this Code and the internal disclosure procedures under the PSDPA are implemented effectively at AAFC and are regularly monitored and evaluated. The Deputy Minister is responsible for ensuring the non-partisan provision of programs and services by AAFC. The Deputy Minister is subject to AAFC’s Code and to the Conflict of Interest Act. 

Employees at AAFC

Federal public servants have a fundamental role to play in serving Canadians, their diverse communities and the public interest under the direction of the elected government and in accordance with the law. As professionals whose work is essential to Canada's well-being and the enduring strength of the Canadian democracy, public servants uphold the public trust.

The Constitution of Canada and the principles of responsible government provide the foundation for the role, responsibilities and values of the federal public sector. Constitutional conventions of ministerial responsibility prescribe the appropriate relationships among ministers, parliamentarians, public servants and the public. A professional and non-partisan federal public sector is integral to our democracy.

AAFC employees are expected to abide by AAFC’s Code and demonstrate the values of the public sector in their actions and behaviours. Employees who are also managers are in a position of influence and authority that gives them a responsibility to exemplify the values of the public sector. 

Values and Ethics Champion at AAFC

At AAFC, the Values and Ethics Champion is a central vehicle for shaping the ethical culture of the department by

  • promoting awareness of public service values and ethics, ethical decision-making and values-based leadership throughout the department
  • establishing a culture of integrity and respect within AAFC by modelling ethical behaviour and communicating the importance of ethical conduct to all employees
  • serving as an additional resource for employees who have questions or concerns about ethical issues in the workplace
  • providing guidance on the mechanisms available to employees for resolving ethical issues.
AAFC’s Workplace Well-Being Ombuds

The Workplace Well-Being Ombuds provides a safe space where any employee can raise work-related issues without fear of reprisal. The role of the Ombuds is to

  • listen to, provide information to, refer and connect employees to existing programs and services
  • provide upward feedback, including to senior management
  • be a resource that is a complementary mechanism to existing systems
  • identify and evaluate options for employees to resolve issues, and, with consent, flag issues to appropriate levels of management
  • identify, synthesize and relay information and observations regarding systemic organizational issues
  • make recommendations to senior management
Senior Officer for Internal Disclosure

The Senior Officer for Internal Disclosure helps promote a positive environment for disclosing wrongdoing and deals with disclosures of wrongdoing made by employees at AAFC. The senior officer is responsible for supporting the Deputy Minister in meeting the requirements of the PSDPA.

The senior officer's duties and powers at AAFC also include the following, in accordance with the internal disclosure procedures established under the PSDPA:

  • provide information, advice, and guidance to public servants at AAFC regarding AAFC's internal disclosure procedures, including the making of disclosures, the conduct of investigations into disclosures, and the handling of disclosures made to supervisors
  • receive and record disclosures and review them to establish whether there are sufficient grounds for further action under the PSDPA
  • manage investigations into disclosures, including determining whether to deal with a disclosure under the PSDPA, initiate an investigation or cease an investigation
  • coordinate handling of a disclosure with the senior officer of another federal public sector organization, if a disclosure or an investigation into a disclosure involves that other organization
  • notify the person(s) who made a disclosure in writing of the outcome of any review and/or investigation into the disclosure, and on the status of actions taken on the disclosure, as appropriate
  • report the findings of investigations, as well as any systemic problems that may give rise to wrongdoing, directly to their Deputy Minister with recommendations for corrective action, if any
AAFC’s Science Integrity Lead

The Assistant Deputy Minister of the Science and Technology Branch is AAFC’s Science Integrity Lead (SIL). The SIL is informed of all allegations of breach of scientific integrity; determines whether the alleged breach constitutes a breach of scientific integrity and whether to respond to the allegation under the AAFC Science Integrity Policy, AAFC’s Science Ethics Policy Framework, AAFC’s Policy on Science and Technology Publications and all other applicable directives, policies or laws. The SIL is also responsible for ensuring that all allegations, investigations and adjudications of breach, and any resulting actions of an allegation, are conducted in a manner consistent with the Principles of Investigation of Alleged Breaches found in the Science Integrity Guidelines: Breaches of Science Integrity. 

Office of the Chief Human Resources Officer (TBS)

In support of the Treasury Board President's responsibilities under section 4 of the PSDPA, the Office of the Chief Human Resources Officer (OCHRO) is responsible for promoting ethical practices in the public sector. The OCHRO will work with all relevant partner organizations to implement and promote the Code and will provide advice to chief executives and designated departmental officials with respect to its interpretation.

The Chief Human Resources Officer may issue directives, standards and guidelines related to AAFC’s Code.

The OCHRO will monitor the implementation of the VECPS, as expressed in AAFC’s Code, with a view to assessing whether the stated objectives have been achieved.

Public Service Commission

The Public Service Commission is responsible for conducting staffing investigations and audits to safeguard the integrity of the public service staffing system and administering certain provisions related to political activities to maintain the non-partisanship of the public service in accordance with the Public Service Employment Act.

Part 3: Conflict of interest

3.1 Requirements for employees to prevent and deal with COI

The following are COI requirements that are a condition of employment for AAFC employees, including the requirements in TBS’s Directive on Conflict of Interest. These requirements serve to uphold the values described in Part 2 of this Code. By upholding these ethical standards, employees maintain public confidence in the honesty, fairness and integrity of the public service. These requirements also form part of Canada's commitments as a signatory to international agreements on values and ethics.

3.2 Conflict of interest and conflict of duties

Conflict of interest

A situation, whether real, apparent or potential, in which the person employed has private interests that could influence the performance of their official duties and responsibilities or in which the person employed uses their office for personal gain.

Conflict of duties

A conflict, whether real, apparent or potential, that arises not because of the private interests of a person employed in the core public administration, but as a result of one or more concurrent and competing official responsibilities.

3.3 Prevention of conflict of interest

AAFC employees maintain public confidence in the objectivity of the public service by preventing and avoiding situations that could give the appearance of a COI, result in a potential for a COI, or result in a real COI.

A COI does not relate exclusively to matters concerning financial transactions and the transfer of economic benefit. While financial activity is important, a COI in any area of activity can have a negative impact on the perceived objectivity of the public service. With the permanent and pervasive nature of information technology, employees should be aware of real, apparent or potential COI that may arise from messages and information shared and transmitted online, including on social media platforms.

It is impossible to foresee every situation that could give rise to a real, apparent or potential COI. When in doubt, AAFC employees should refer to the requirements found in AAFC’s Code to guide appropriate action. Employees can also seek guidance from their manager or the VEPC.

In addition to the requirements outlined in this Part of AAFC’s Code, employees are also required to observe any specific conduct requirements contained in the statutes governing AAFC and their profession, where applicable.

3.4 Responsibilities and duties of AAFC employees

AAFC employees’ responsibilities and duties include complying with the requirements in the Directive on Conflict of Interest, which is a condition of employment, including:

3.4.1 General requirements

  • Identifying, preventing and resolving conflict of interest and conflict of duties situations during their employment in the public service and conflict of interest situations when they leave the public service
  • Reporting in writing to their deputy head all outside employment and activities, assets, liabilities and interests that might give rise to a real, apparent or potential conflict of interest in relation to their official duties and responsibilities
  • Refraining from having private interests and engaging in outside employment or activities that may subject them to demands incompatible with their official duties, or that could be seen to impair their ability to perform their duties and responsibilities in an objective and impartial manner
  • Reporting in writing to their deputy head before engaging in non-candidacy political activities that could constitute a conflict of interest or impair their ability to perform their duties and responsibilities in an objective and impartial manner
  • Reporting in writing to their deputy head when concurrent or competing official responsibilities give rise to a conflict of duties situation

3.4.2 Contracts with the Government of Canada, non-public information, preferential treatment and inappropriate influence

  • Obtaining the approval of their deputy head before entering into a contract or contractual arrangement for which they may receive any direct or indirect benefit or income from the Government of Canada
  • Refraining from knowingly taking advantage of or benefiting from information that is obtained in the course of their duties and responsibilities that is not available to the public
  • Refraining from assisting outside entities or individuals in their dealings with the government where doing so would result in preferential treatment or advantages to the entities or individuals
  • Refraining from interfering in the dealings of outside entities or individuals with the government in order to inappropriately influence the outcome

3.4.3 Gifts, hospitality and other benefits

  • Refusing gifts, hospitality or other benefits if they may have a real, apparent or potential influence on the objectivity of the person employed in carrying out their official duties and responsibilities or may place the person employed under the obligation of the donor
  • For greater certainty, accepting gifts, hospitality or other benefits is permissible if they: are infrequent and of minimal values; are within the normal standards of courtesy or protocol; arise out of the official duties and responsibilities of the person employed; and do not compromise the integrity of the person employed or the organization
  • Reporting and seeking written direction from their deputy head when they cannot decline gifts, hospitality or other benefits that do not meet the criteria in subsection j to l or where it is believed their acceptance would bring sufficient benefit to the organization
  • Reporting and seeking written direction from their deputy head when a family member or friend applies for a position for which the employee oversees before undertaking any staffing actions including assessment processes

3.4.4 Financial arrangements, solicitation and use of government property

  • Refraining from undertaking any financial arrangements, including procuring goods, contracting services or administering grants and contributions or transfer payments, with outside entities or individuals where there is a risk for a real, apparent or potential conflict of interest or conflict of duties situation
  • Refraining from soliciting gifts, hospitality, other benefits or transfers of economic value from outside entities or individuals that have, had or may have dealings with the organization, including during fundraising activities for the Government of Canada Workplace Charitable Campaign, without having received prior written approval from their deputy head
  • Refraining from the direct or indirect use of, or allowing the direct or indirect use of, government property of any kind, including property leased to the government, for anything other than officially approved activities

3.5 Requirements for preventing and dealing with situations of COI during employment

AAFC employees are required to report in writing to the Deputy Minister or their delegate all outside activities, assets and interests that might give rise to a real, apparent or potential COI in relation to their official duties. Such a report is to be made within 60 days of their initial appointment or any subsequent appointment, transfer or deployment. Reports should be made using AAFC’s COI Disclosure Form (PDF) and submitted to the VEPC.

On a regular basis thereafter, and every time a major change occurs in their personal affairs or official duties, employees are required to review their obligations under AAFC’s Code, which includes the obligations of the VECPS and TBS’s Directive on Conflict of Interest. If a real, apparent or potential COI exists, they must submit a COI Disclosure Form in a timely manner.

In addition, AAFC may require employees to attest regularly throughout the performance management cycle that they understand their obligations under the Code and indicate whether they need to submit a new or revised COI disclosure.

When negotiating financial arrangements with outside parties, employees are to comply with the requirements listed in the AAFC Code as well as other related directives or policies issued by TBS. When in doubt, employees are to immediately report the situation to their managers to seek advice or direction on how to proceed.

Assets

Employees are required to evaluate their assets, taking into consideration the nature of their official duties and the characteristics of their assets. If there is any real, apparent or potential COI between the carrying out of their official duties and their assets, they are to report this matter to the Deputy Minister or their delegate in a timely manner, using the COI Disclosure Form submitted to the VEPC.

Where the Deputy Minister or their delegate determines that any of these assets results in a real, apparent or potential COI in relation to their official duties, employees may be required to divest those assets, or to take other measures to resolve the conflict. Employees may not sell or transfer assets to family members or anyone else for the purpose of circumventing the compliance requirements.

The types of assets that should be reported and the procedures for reporting and managing such assets are set out in Appendix B: Standard on Preventing and Resolving Financial Conflicts of Interest of TBS’s Directive on Conflict of Interest.

AAFC related assets

If an AAFC employee or their immediate family members (including immediate family of the employee's spouse) owns land used or rented for farming, invests in businesses related to agriculture or agri-food, or is considering such ownership or investments, those assets must be disclosed using the COI Disclosure Form.

Outside employment or activities

AAFC employees may engage in employment outside the public service and take part in outside activities unless the employment or activities are likely to give rise to a real, apparent or potential COI or would undermine the impartiality of the public service or the objectivity of the employee.

Employees are required to report to the Deputy Minister or their delegate when their outside employment or activities might subject them to demands incompatible with their official duties or cast doubt on their ability to perform their duties or responsibilities in a completely objective manner. The Deputy Minister or their delegate may require that the outside activities be modified or terminated if it is determined that a real, apparent or potential COI exists.

Employees must obtain the approval of the Deputy Minister or their delegate before entering a contract or contractual arrangement for which they may receive any direct or indirect benefit or income from the Government of Canada. The Deputy Minister or their delegate will determine whether the arrangement presents a real, apparent or potential COI, and may require that the contract be declined, modified or terminated.

AAFC related outside employment or activities

If an AAFC employee participates in, or is considering participation in, any of the following activities, those activities must be disclosed using the COI Disclosure Form:

  • carrying out farming activities as a hobby or for commercial farming purposes, including activities of the employee or their immediate family members (including immediate family of the employee's spouse); or
  • applying for or receiving benefits under any grant, contribution, income assistance program or any other program administered by AAFC, whether as an individual or as part of an organization that applies for or receives benefits.

At no time should an AAFC employee assist the public on a fee-for-service basis in completing application forms for funding from a program administered by AAFC.

If an AAFC employee is a member of a board of directors of a corporation, society, organization or external entity as an outside activity, and the board activities relate to the employee's official duties, AAFC activities, or has dealings with AAFC, such activities must be disclosed and assessed further to AAFC’s Directive for Assessing Employee Memberships on External Boards of Directors (DOC).

Political activities

Any employee considering involvement in political activities should seek the advice of their manager, an AAFC Designated Political Activities Representative or the Public Service Commission before acting.

Employees are required to obtain permission from the PSC prior to seeking nomination for or becoming a candidate in a federal, provincial, territorial or municipal election, in accordance with Part 7 of the Public Service Employment Act (PSEA).

"Political activities" are defined in Part 7 of the PSEA as "any activity in support of, within or in opposition to a political party; carrying on any activity in support of or in opposition to a candidate before or during an election period; or, seeking nomination as or being a candidate in an election before or during the election period."

Employees who wish to engage in a political activity not covered by Part 7 of the PSEA that could constitute a COI are required to report the proposed activity to the Deputy Minister or their delegate.

Similarly, any employee who is subject to AAFC’s Code but who is not to Part 7 of the PSEA, including casual and part-time workers, who wish to engage in any political activity that could constitute a COI, is to report the proposed activity to the Deputy Minister or their delegate.

Gifts, hospitality and other benefits

AAFC employees are expected to use their best judgment to avoid situations of real, apparent or potential COI by considering the following criteria on gifts, hospitality and other benefits and in keeping with the AAFC Code, which includes the obligations of the VECPS and the Directive on Conflict of Interest.

Employees are not to accept any gifts, hospitality or other benefits that may have a real, apparent or potential influence on their objectivity in carrying out their official duties and responsibilities or that may place them under obligation to the donor. This includes activities such as free or discounted admission to sporting and cultural events, travel or conferences.

The acceptance of gifts, hospitality and other benefits is permissible if they are infrequent and of minimal value, within the normal standards of courtesy or protocol, arise out of activities or events related to the official duties of the employee, and do not compromise or appear to compromise the integrity of the employee or the department. Employees can use AAFC’s Acceptance of hospitality and other benefits flowchart to assist them in determining whether acceptance of an offer is allowable under AAFC’s Code.

Employees must seek written direction from the Deputy Minister or their delegate where it is impossible to decline gifts, hospitality or other benefits that do not meet the principles set out above, or where it is believed that there is sufficient benefit to AAFC to warrant acceptance of certain types of hospitality. The COI Disclosure Form may be used for this purpose.

Gifts, hospitality and benefits from Indigenous communities

AAFC is mindful of Indigenous traditions and culture with regards to gifts, hospitality and benefits. Gifting is a sign of thanksgiving and is part of the Indigenous way. It often demonstrates respect and appreciation of one's knowledge and effort in reaching common goals. Employees must balance refusal of an offering which might offend, with accepting it, which could create a COI.

When a departmental official is offered a gift that is not of minimal value, or when in doubt about the value of a gift, the refusal of which would not be appropriate due to cultural sensitivities, the gift may be accepted on behalf of AAFC. Employees should discuss it with their supervisor and submit a COI Disclosure Form to the VEPC.

  • AAFC employees, when visiting a First Nations community, may accept a simple meal, rides to and from the airport, as well as small gifts such as pens, mugs and other items of minimal value.
  • Gifts of more than minimal value such as paintings, blankets carvings, an ornate dream catcher, moccasins, gloves or mitts, can be accepted on behalf of the department and a COI Disclosure Form must be filed and sent to the VEPC.
Offers of funded travel from a third party

AAFC employees collaborating with various stakeholders while carrying out the department's mandate may receive offers from stakeholders to pay costs related to travel by the employee. Accepting such an offer could compromise the impartiality and objectivity of the employee, or create a perception of preferential treatment towards the donor in future decisions.

If a third party offers to pay or reimburse the costs related to travel by an employee, the employee may accept the offer, unless the offer poses a significant risk of real, apparent or potential COI, and unless the acceptance of the offer would contravene any other legal, financial or policy requirements.

AAFC employees must not accept any offer of funded travel from a third party if

  • the offer is not in the interest of AAFC or the Government of Canada;
  • the offer of funded travel was solicited;
  • the offer was made to an employee in an executive (EX) position, or an equivalent position that has delegated financial authority;
  • the third party is a current supplier to AAFC, unless they exclusively provide agricultural or agri-food publications or have a formal agreement with AAFC covering funded travel;
  • the third party actively lobbies AAFC; or
  • the third party receives grants or contributions from AAFC, unless there is a cost-sharing agreement that exists between AAFC and the organization.

In other situations, employees who receive offers of funded travel must follow AAFC’s Directive for Assessing Offers of Travel Funded by a Third Party to determine whether the offer may be accepted.

Solicitation of gifts, hospitality or other benefits

AAFC employees may not solicit or accept gifts, hospitality, other benefits or transfers of economic value from a person, group or organization in the private sector who has dealings with the government, or with AAFC, including as part of departmental fundraising activities or events.

Similarly, if an outside individual or entity, with whom AAFC has past, present or potential official dealings, offers a benefit to AAFC such as funding for an event or a donation of equipment, employees are to consider whether any real, apparent or potential COI exists, and obtain the consent in writing of the Deputy Minister or their delegate prior to accepting any such benefit.

The Deputy Minister or their delegate may require that the activities be modified or terminated where it is determined that there is a real, potential or apparent COI or an obligation to the donor. These provisions are designed to ensure that AAFC’s Code is consistent with paragraph 121(1)(c) of the Criminal Code.

Avoidance of preferential treatment

AAFC employees are responsible for demonstrating objectivity and impartiality in the exercise of their duties and in their decision-making, whether related to staffing, financial awards or penalties to external parties, transfer payments, program operations or any other exercise of responsibility.

This means that they are prohibited from granting preferential treatment or advantages to family, friends or any other person or entity that may be perceived as causing bias. They are not to offer extraordinary assistance to any entity or persons already dealing with the government without the knowledge and support of their supervisor. They also are not to disadvantage any entity or persons dealing with the government because of personal antagonism or bias.

Employees must avoid COI related to staffing processes and decisions. If a family member or friend applies for a position within the department for which the employee has oversight, they must immediately disclose the relationship to their manager and recuse themselves from all activities of the hiring process. Additionally, if the individual is hired and a reporting relationship will exist between the employee and the hired individual, the employee in the supervisory role must disclose the relationship by submitting a COI Disclosure Form to the VEPC to ensure that COI mitigating measures are established.

Providing information that is publicly accessible is not considered preferential treatment.

Boards of directors

AAFC employees may be expected to serve on or be a member of a board of directors of an organization, society or association external to the Government of Canada in relation to their official duties, which can involve significant risks of real, apparent or potential COI or conflict of duties.

This means that all employees who currently serve on or are thinking of joining a board of directors or other executive body of an external organization in relation to their official duties must assess their participation further to AAFC’s Directive for Assessing Employee Memberships on External Boards of Directors.

AAAFC employees who serve on boards of directors must continue to respect the provisions of AAFC’s Code, including the following obligations:

  • do not lobby the Government of Canada;
  • do not represent the organization in dealings with the Government of Canada; and
  • do not provide assistance to the organization in its dealing with the Government of Canada, such as helping to obtain funding, where this could be perceived as preferential treatment.

Any COI or conflicts of duties inherent in the participation on the board of directors must be resolved in the public interest.

Canadian Pari-Mutuel Agency

The Canadian Pari-Mutuel Agency (CPMA) is a Special Operating Agency within AAFC that regulates and supervises pari-mutuel betting on horse racing at racetracks across Canada. Further to this mandate, and in addition to the requirements of the AAFC Code, employees at the CPMA are prohibited from:

  • placing wagers at the racetracks or any theatre betting establishment while on duty, including any breaks;
  • cashing cheques at the racetrack institutions; and
  • having any financial interests in the racetrack facilities including owning/co-owning horses who race in any racetrack institution.
Adjunct affiliations

AAFC has a long history of collaborating with academia and hosting graduate students at AAFC facilities. Maintaining adjunct affiliation status may be a university prerequisite for researchers and science professionals to participate in graduate student thesis committees. However, there is no AAFC requirement for researchers and professionals to undertake such adjunct affiliation. Adjunct affiliations can give rise to challenges navigating between academic institution activities and employees’ obligations as federal public servants. AAFC managers, researchers and professionals can refer to AAFC’s Standard on Adjunct Affiliations to ensure consistency in application, awareness of expectations, and alignment to Government of Canada legislation and policies.

3.6 Requirements for preventing post-employment COI situations before and after leaving office

All public servants have a responsibility to minimize the possibility of real, apparent or potential COI between their most recent responsibilities within the federal public service and their subsequent employment outside the public service.

Before leaving employment

Before leaving their employment with the public service, all employees are to disclose their intentions regarding any future outside employment or activities that may pose a risk of real, apparent or potential COI with their current responsibilities and discuss potential conflicts with their manager or the VEPC.

Post-employment limitation period for employees in designated positions

Certain positions at AAFC involve official duties that raise post-employment concerns. These positions include all those classified as executive (EX) positions, those classified as EX minus 1, EX minus 2, and their equivalents. AAFC may designate certain other positions as ones that raise post-employment concerns, based on an assessment of the COI or post-employment risks inherent in the official duties of the positions.

AAFC employees in these designated positions are subject to a one-year limitation period after leaving the public service. Before leaving the public service and during this one-year limitation period, these employees are to report in writing to the Deputy Minister or their delegate all intended future employment and activities that might give rise to a real, apparent or potential COI in relation to their most recent duties and responsibilities. They are also to disclose immediately the acceptance of any such offer. The COI Disclosure Form may be used for this purpose.

In addition, these employees may not, during this one-year period, without the written approval of the Deputy Minister or their delegate:

  • accept an appointment to a board of directors of, or employment with, outside entities or individuals with which they had significant official dealings, either directly or through their subordinates, in the year immediately prior to leaving their employment in the public service;
  • make representations on behalf of entities or individuals outside the public service to any government organization with which they had significant official dealings, either directly or through their subordinates, in the year immediately prior to leaving their employment in the public service;
  • give advice to their clients or any new employer by using information that is not publicly available concerning the programs or policies of the department or organization with which they were employed or with which they had a direct and substantial relationship.

Waiver or reduction of limitation period

An AAFC employee or former employee may apply to the Deputy Minister or their delegate for a written waiver or reduction of the limitation period. If applying for a waiver or reduction of the one-year post-employment limitation period, as a minimum, the following information is required:

  • the circumstances under which they are leaving or left their public service employment;
  • their general employment prospects;
  • the significance to the government of information possessed by virtue of their position in the public service;
  • the desirability of a rapid transfer of their knowledge and skills from the government to private, other governmental or non-governmental sectors;
  • the degree to which their new employer might gain unfair commercial or private advantage;
  • the authority and influence they possessed while in the public service; and/or
  • any other consideration at the discretion of the Deputy Minister or their delegate.

3.7 Resolution

With respect to the arrangements necessary to prevent real, apparent or potential COI, or to comply with the requirements set out above, it is expected that situations will be resolved through discussion and agreement between the employee and the Deputy Minister or their delegate. When an employee and the Deputy Minister or their delegate disagrees on the appropriate arrangements to resolve a real, apparent or potential COI, the disagreement will be resolved through the established grievance procedures.

3.8 Consequences

An employee who does not comply with the requirements set out in AAFC’s Code may be subject to disciplinary measures, up to and including termination of employment.

Part 4: Additional guidance

4.1 Definitions

AAFC employee

A person employed at AAFC, including managers and executives, indeterminate and term employees, individuals on leave without pay, students participating in student employment programs, casual, seasonal and part-time workers and persons working by means of a secondment. Although they are not public servants, individuals on incoming Interchange Canada assignments, volunteers, emeritus scientists and contractors are expected to comply with the requirements of the AAFC Code. Order-in-council appointees, such as deputy heads, are subject to the Conflict of Interest Act.

Adjunct affiliation

Any affiliation with an academic institution, in or outside of Canada. While predominantly referred to as adjunct professors, terminology varies and includes adjunct lecturer, adjunct research professor, associated graduate faculty and special graduate faculty, among others.

Conflict of duties

A conflict, whether real, apparent or potential, that arises not because of the private interests of a person employed in the core public administration, but as a result of one or more concurrent and competing official responsibilities.

Conflict of interest

A situation, whether real, apparent or potential, in which the person employed has private interests that could influence the performance of their official duties and responsibilities or in which the person employed uses their office for personal gain.

Designated Political Activities Representative

The Deputy Minister’s delegate to receive employees’ requests and queries regarding political activities, coordinate and prepare related material for the Deputy Minister’s consideration and liaise with the Public Service Commission as required for consideration and final approval.

Discrimination

Treating people differently, negatively or adversely because of their race, national or ethnic origin, colour, religion, age, sex (including pregnancy and childbearing), sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, physical or mental disability (including dependence on alcohol or drugs) or pardoned criminal conviction.

Ethical dilemma

A situation where an employee faces a conflict between two or more values or rules. In such cases, there may be no right answer and any decision made could be a case of choosing one ethical principle over another.

Fairness

One of the guiding values of the Public Service Employment Act. It requires that decisions be made objectively and free from political influence and personal favouritism; policies and practices reflect the just treatment of persons; who also have the right to be assessed in the official language(s) of their choice in an appointment process.

Family

Includes common-law partner, child, spouse, family members and persons who are related to an employee by birth, marriage, common-law partnership, adoption or affinity.

Harassment

Any improper conduct by an individual that is directed at and offensive to another person or persons in the workplace and that the individual knew or ought reasonably to have known would cause offence or harm. It comprises any objectionable act, comment or display that demeans, belittles or causes personal humiliation or embarrassment, and any act of intimidation or threat. It includes harassment within the meaning of the Canadian Human Rights Act and based on protected grounds set out in that Act, namely race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, disability and pardoned conviction.

Non-partisanship

One of the core values of the Public Service Employment Act. It is essential to a professional public service and responsible democratic government and ensures that appointments and promotions to and within the public service are based on merit and free from political influence. It supports the capacity and willingness of employees to serve governments regardless of political affiliation. It enables employees to provide objective policy advice and administer programs and services for Canadians in a politically impartial manner.

Political activities

Carrying on any activity in support of, within or in opposition to a political party; carrying on any activity in support of or in opposition to a candidate before or during an election period; or seeking nomination as or being a candidate in an election before or during the election period.

Senior Officer for Internal Disclosure

Deputy Minister’s delegate responsible for the receipt and proper treatment of disclosures made by public servants under the Public Servants Disclosure Protection Act.

Third party

Any individual, group or organization external to the Government of Canada, such as a private individual, a business, a society, an association or a university.

Third party-funded travel

A private organization covers the costs (transportation, accommodations, meals) for a public servant to travel and carry out official duties at a specific location.

Wrongdoing

Relates to serious violations that go against the public interest, such as:

  • violating any Act of Parliament or any Act of the legislatures of the provinces or territories
  • misusing public funds or public assets
  • gross mismanagement
  • doing something, or failing to do something, that creates a substantial and specific danger to the health, safety or life of persons or to the environment
  • seriously breaching the VECPS or AAFC Code
  • directing or counselling someone to commit a wrongdoing

4.2 Tools and references

References that relate to AAFC’s Code; this list is by no means exhaustive, but it includes the most relevant material.

4.2.1 Acts and laws

4.2.2 TBS policies and directives

4.2.3 AAFC guidelines and tools

4.2.4 Mandatory and other training

4.2.5 Other resources

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