Office of the Auditor General of Canada Code of Values, Ethics, and Professional Conduct

I—Introduction

The Office of the Auditor General (OAG) audits federal government operations and provides Parliament with independent information, advice, and assurance regarding the federal government’s stewardship of public funds. Through our work, we contribute in a fundamental way to good government, democracy, and Canadian society.

This Code outlines the values and ethics that guide and support employees in their professional activities. It serves to preserve a professional work environment and enhance the public and government’s confidence in the integrity of the Office. The Code also strengthens respect for, and appreciation of, the role played by the Office within Canadian democracy.

Our Code is founded on the fundamental principles outlined in the Values and Ethics Code for the Public Sector and tailored to apply to the OAG mandate and environment.

Effective date

This Code is effective as of 4 October 2012.

Application

All those who perform work for or on behalf of the Office are required to comply with this Code as well as observe the duties and responsibilities outlined in the Values and Ethics Code for the Public Sector (Public Sector Code).

This includes

  • OAG employees,
  • temporary help,
  • outside consultants and contractors,
  • public servants on secondment to the Office, and
  • international Fellows.

Acceptance of and adherence to these values and behaviours is a condition of employment or contract.

Persons acting as advisors on audits or on panels advising the Auditor General (AG) are required to follow the spirit and intent of the Code insofar as they may apply to their relationships to the AG or the Office.

When faced with a possible ethical dilemma, Office employees are encouraged to discuss the matter with their supervisor(s) and to use any opportunities and mechanisms provided in the Office to raise, discuss, and resolve issues of concern related to this Code.

Legislative and policy compliance

In addition to the requirements outlined in this Code, those working on behalf of the Office are also required to observe any specific conduct and other requirements contained in applicable statutes, including the following:

Office employees must also comply with Office policies and applicable Treasury Board policies. Employees who are uncertain of the application of the provisions of laws or policies to their particular circumstances should consult Legal Services.

Exceptions and exemptions

Persons who feel that all or part of this Code should not apply to them, due to the nature of their relationship with the Office, should raise the matter with their supervisor(s). Exemption from the application of this Code may be made by the Auditor General, or his designate.

Employees who belong to a professional association are governed by the codes and by-laws of that body. While this Code is intended to be consistent with those of professional associations, there may be cases where it is more specific or demanding. In such cases, this Code prevails.

In rare cases, the professional association’s code may prescribe conduct that appears to conflict with this Code. In such a situation, the matter should be brought immediately to the attention of the employee’s supervisor(s) and Assistant Auditor General (AAG).

Breaches

Any employee who witnesses or has knowledge of a probable ethical breach or of wrongdoing in the workplace should refer the matter in confidence and without fear of reprisal to Legal Services or to the Senior Officer for Disclosure.

Any employee who believes that he or she is being asked to act in a way that is inconsistent with the Office’s values and ethics should report the matter. As provided by sections 12 and 13 of the Public Servants Disclosure Protection Act, if employees have information that could indicate a breach of this Code, they can bring this matter to the attention of their immediate supervisor(s), the Senior Officer for Disclosure, or the Public Sector Integrity Commissioner. A breach of this Code or the Public Sector Code may result in disciplinary measures up to and including termination.

Investigation, resolution, and recourse

The Office’s Policy on Workplace Investigations and discipline guidance will direct all review, resolution, and recourse activities related to this Code.

If, in the employee’s opinion, a breach is not appropriately addressed within the Office, or there is reason to believe it could not be disclosed in confidence within the Office, it may be referred to the Public Sector Integrity Commissioner.

II—Office Values

A balanced framework of values underlies all Office activities and plays a key role in recruitment, management, evaluation, and promotion.

Our values are

Democracy and independence

We are an agent of Parliament that is independent of government. Our reports are based on evidence collected according to our policies and professional auditing standards. We bring a non-partisan, objective, and fair approach to our work.

Upholding the system of Canadian parliamentary democracy and its institutions is fundamental to serving the public interest. In support of this goal, we perform the following functions: 

  • A non-partisan public sector is essential to our democratic system.
  • We respect the rule of law by observing the letter and spirit of the Auditor General Act and other applicable legislation and policies.
  • We carry out our duties honestly, impartially, and in a non-partisan manner.
  • We openly and candidly provide those responsible in the Office for making decisions with all relevant information, analysis, and advice.
  • We comply with legislation.
  • We support both individual and collective accountability.
  • We keep Parliament and Canadians informed of the results of our work.

Respect for people

We are committed to providing a working environment in which all are treated with dignity and respect and supported to realize their full career potential. We encourage open and honest communication to create a climate of trust and teamwork. We value each other’s talent and diversity and support learning and work-life balance in the following ways:

  • We demonstrate respect, fairness, and courtesy in our dealings with citizens and fellow employees.
  • We respect human dignity and the value of every person.
  • We treat people with respect and fairness.
  • We value differences between individuals and the benefit of combining the unique qualities and strengths inherent in a diverse workforce.
  • We help to create and maintain safe and healthy workplaces that are free from harassment and discrimination.
  • We work together in a spirit of openness, honesty, and transparency, encouraging collaboration and respectful communication.
  • We not only meet our legislated responsibilities but foster a culture and a working environment in which both official languages are recognized, used, and promoted.

Integrity and professionalism

We sustain public confidence by conducting ourselves, in everything we do, with honesty and integrity and in a manner that meets the highest standards of professional conduct. Personal and professional integrity are essential requirements for those performing work for or on behalf of the Office. We uphold these values in the following ways:

  • We perform our duties and arrange our private affairs so that public confidence and trust in the integrity, independence, objectivity, and impartiality of the Office are protected.
  • We act at all times in such a way as to uphold the public interest and the Office’s trust.
  • We act at all times in a manner that will bear the closest public scrutiny—an obligation that is not fully discharged by simply acting within the law.
  • We never use our positions to gain unfair advantage, whether pecuniary or non-pecuniary, in our personal affairs.
  • We are entrusted to use and care for public resources responsibly, to achieve both short- and long-term goals.
  • We resolve conflicts between our private interests and our official duties in favour of the public interest.
  • We conduct ourselves in a professional manner at all times.
  • We serve with competence, efficiency, objectivity, and impartiality.
  • We provide fair and timely services that respect diversity and Canada’s official languages.

Stewardship and serving the public interest

We focus on significant issues to make a positive and measurable impact. In particular, we promote government accountability for the collection and use of public funds and for the results achieved in the following ways:

  • We contribute to the improvement of the economy, efficiency, effectiveness, and environmental sustainability of government policies, programs, and services.
  • We strive to ensure that the values of transparency and accountability in government are upheld while respecting our duties of confidentiality under the law.
  • We make decisions in the public interest.
  • We consider the present and long-term effects that our actions may have on people and the sustainability of the environment.

Commitment to excellence

We meet the highest standards of professionalism in our work with Parliament and those we audit. We are committed to continuously improving our processes and practices and delivering products and services of the highest quality. We share our experience with others and contribute to the advancement of the legislative audit discipline in Canada and abroad.

We strive to be a model organization for the federal government. We treat people fairly. Our audit plans are strategic and risk-based, our reports are focused on results, and our effectiveness is measured and reported annually to Parliament. Our policies and practices are aligned with our vision and values, and our processes are economical, efficient, and responsive.

In support of all of these goals, we do the following:

  • We seek to achieve the highest standards of behavior, competence, and excellence in our work.
  • We promote engagement, collaboration, effective teamwork, learning, and innovation as they are essential to a high-performing organization.
  • We apply our expertise in areas of highly specialized knowledge or technical skill.

III—Responsibilities, Authorities, and Accountabilities

All Office activities should be consistent with this Code. Specific accountabilities, authorities, and responsibilities are assigned to the following:

Auditor General

The Auditor General (AG) is responsible for preserving public confidence in the integrity of management and operations within the Office. The AG is also responsible for maintaining the independence and objectivity of the Office and its continuing ability to provide professional, candid, and frank advice.

In particular, the Auditor General has the following obligations:

  • to ensure that the Office and its personnel comply with professional standards and applicable legal and regulatory requirements;
  • to ensure that the Office’s reports are appropriate in the circumstances;
  • to provide an internal culture focused on quality and on establishing operational priorities that emphasize the quality of the work performed;
  • to ensure that the letter of offer, for an initial appointment, includes the following statement: “You will find enclosed a copy of the Values and Ethics Code for the Public Sector and our organizational Code of Values, Ethics, and Professional Conduct. These codes are key Office policies and form part of your conditions of employment.”;
  • to ensure that those working on behalf of the Office are reminded each year of the Code’s requirements;
  • to encourage and maintain an ongoing dialogue on Office values and ethics in a manner that is relevant to the specific issues and challenges encountered by the Office;
  • to ensure that mechanisms and assistance are in place to help Office employees raise, discuss, and resolve issues of concern related to this Code (this includes designating Legal Services to assist Office employees to resolve issues arising from the application of the Code);
  • to determine the appropriate method for employees to comply with the Code in order to avoid conflicts of interest;
  • to ensure that the personal information in confidential reports is secured in a central repository and treated in complete confidence, in accordance with the Privacy Act; and
  • to ensure that employees who are intending to leave the Office are aware of the post-employment measures.

The Auditor General may delegate responsibilities and authorities for the implementation of this Code, but he may not delegate accountability for ensuring that the Code is fully upheld and advanced within the Office or for the specific matters outlined within it.

Executive Committee

The Auditor General (AG), Deputy Auditor General (DAG), if any, the Commissioner of the Environment and Sustainable Development (CESD), and Assistant Auditors General (AAG) are members of the Office’s Executive Committee. They have a particular responsibility to exemplify, in their actions and behaviours, the values of public service set out in this Code and to promote an internal culture focused on quality and compliance with Office policies and procedures. It is expected that they will take special care to ensure that they comply at all times with both the spirit and the specific requirements of this Code.

The AG, DAG, CESD, and AAGs are accountable for

  • infusing these values into all aspects of the work of the Office;
  • ensuring that those working for or on behalf of the Office are aware of, and comply with, their obligations under this Code; 
  • providing appropriate advice within the Office on ethical issues, including possible conflicts of interest; and 
  • applying the requirements of the Code to all employees in a fair, objective manner.

The Office’s operations are funded by taxpayers in the same way as any federal department or agency. Since the Office is an advocate for economy, efficiency, and effectiveness in the conduct of government operations as a whole, it too has an obligation to observe these principles. The Office’s Executive Committee is accountable for ensuring that the OAG functions as a model for the rest of the public service.

Senior Officer for disclosure

The Senior Officer for disclosure is responsible for supporting the Auditor General as chief executive in meeting the requirements of the Public Servants Disclosure Protection Act. He or she helps promote a positive environment for disclosing wrongdoings, and helps to deal with disclosures of wrongdoing made by employees of the organization. The duties and powers of Senior Officers for disclosure are set out in the Public Service Code.

OAG employees

All employees of the Office shall

  • observe the conditions of employment established for their work;
  • respect the confidentiality of internal documentation and communications;
  • conduct themselves according to the affirmations made by them in their Oath of Office and Secrecy; and
  • review the Code annually as part of the Confidential Declaration process. 
Respectful workplace

The OAG’s Respectful Workplace Policy applies to all employees.

Every person working for or on behalf of the Office has a right to work in an environment free of harassment and discrimination. Harassment and discrimination detrimentally affect the work environment and may lead to adverse job-related consequences for the victim. As a result, such conduct is viewed as professional misconduct and will be subject to disciplinary measures up to and including suspension and termination.

The Office will follow up appropriately if advised that those working for or on behalf of the OAG are being treated disrespectfully by external contacts, such as entity representatives or members of the public. 

Occupational health and safety

The Office has an obligation to protect the health and safety of Office employees while they are at work. The specific elements of this obligation are set out in Part II of the Canada Labour Code. Those working on behalf of the Office have a corresponding obligation to carry out the employees’ duties under the Code, including

  • complying with all instructions from the employer concerning the health and safety of employees;
  • cooperating with the policy and workplace committees or the health and safety representative;
  • reporting anything in a workplace (onsite or off-site) that is likely to be hazardous to the health or safety of the employee, or that of the other employees or other persons granted access to the workplace by the Office; and
  • reporting every accident or other incident arising in the course of, or in connection with, the employee’s work that has caused injury to the employee or to any other person.

The Office has an obligation to ensure that the locations employees work in are safe and, to the extent possible, do not create or aggravate health problems. Employees should discuss, with their supervisor(s), any issues or concerns they have relating to the health or safety of onsite and off-site premises. The Office will address the matter in such a way as to ensure that the health and safety of its employees and other representatives are protected.

Membership in professional associations

Employees who are members of professional associations in connection with their duties in the Office are expected to maintain themselves as members in good standing of such associations during their tenure with the Office. A professional designation is an indicator of the achievement of a level of competence or expertise in a particular field. The loss or lapse of such a designation could be significant to an employee’s ability to carry out his or her duties on behalf of the Office. Employees must discuss with their supervisor(s) any loss or lapse in membership in a professional association.

External communications and reporting

The OAG’s primary reporting relationship is to Parliament, through the tabling of reports and through the Public Accounts Committee or to the boards of directors of Crown-owned corporations; it is not directly to the public. The overriding responsibility of the Office to Parliament or to the boards of directors of Crown corporations precludes the release of information, except in accordance with statutory requirements.

The Office communicates to the public through the mass communications media only after it has presented its results to Parliament, Boards of Directors of Crown corporations, and provincial and territorial governments.

All public communications (for example, speeches, press releases, conference speeches, Twitter, or other social media) from the Office can be undertaken only after appropriate authorization is received from senior management.

The communication policy suite provides detailed direction in this regard.

Confidentiality of Office information

Employees and contractors are required to strictly maintain the confidentiality of Office information and information provided by our audited entities. Employees should take care not to divulge such information, including to their family and friends, and to share the information only with other employees who have a need to know, unless otherwise directed by their supervisors. Since accidental disclosure can also be damaging, employees should take every precaution not to discuss confidential matters in public places and to safeguard documents appropriately. The obligation to maintain the confidentiality of entity and Office information continues after an employee has left the Office.

For more information, employees should consult the Office’s Security policy.

Employees and contractors working on assurance engagements

All employees or contractors participating in an assurance engagement and all other persons who can directly influence the outcome of an assurance engagement must comply with Office policies, professional standards, the Office’s system of quality control, and related methodology. Therefore, each person participating in or directly influencing the outcome of an assurance engagement must comply with the “Ethical requirements relating to an assurance engagement” set out in Section 1031 of the audit manuals and the Independence policies and procedures as set out in Section 3031 of the manuals.

Consultants and contractors

The Office wishes to preserve and maintain the cooperative and mutually beneficial relationships it has with management consulting and accounting firms. At the same time, the Office must be able to demonstrate conclusively that contracts have not been subject to influence (for example, by a former Office employee currently with the firm in question or by a former employee of the firm currently employed by the Office). Contract procedures should ensure that the Office is protected from even the suspicion of conflict of interest.

Employees involved in contract negotiations have a duty to ensure that contracts entered into by the Office are the result of well-established procedures and are above suspicion with regard to the validity of the criteria used in awarding them.

The Office would not knowingly assign a consultant to an audit entity where the consultant (individual or firm) is, has recently been, or may be contractually engaged. Therefore, the Office requires a history of the consultant’s business dealings with the audit entity covering the previous two years. The Office will then decide whether the likelihood exists for a potential conflict of interest. In the same fashion, the Office needs to be informed of any bid by the consultant or the firm in relation to the audit entity.

Consultants and firms contractually engaged by the Office are required to provide a complete list, to the best of their knowledge, of current and recent contracts undertaken with an audit entity examined on their own behalf or on behalf of a client who has significant involvement with the audit entity. They are also responsible for informing the responsible audit principal of any bid, within their knowledge, that they or their firms intend to make in relation to any entity they are auditing or in which they are working on behalf of the Office.

External panel advisors may be exempted from the above with the Auditor General’s approval. 

IV—Conflict of Interest

Office employees maintain public confidence in the impartiality and objectivity of the Office by avoiding and preventing situations that could give rise to a conflict of interest, or the appearance of, or a potential for, a conflict of interest. These conflict of interest measures are adopted both to protect Office employees from conflict of interest allegations and to help them avoid situations of risk.

To demonstrate their understanding of these fundamental principles and compliance with Office protocols, employees are required to review this Code annually and complete the Confidential Declaration Form within the allotted timeline. The Confidential Declaration outlines the employee’s ownership of assets; receipt of gifts, hospitality, or other benefits; and participation in any outside employment, activities, or personal relationships that may give rise to a potential or real conflict of interest. Confidential Declarations are filed on commencing employment with the Office, annually thereafter, and when there is any change in an employee’s situation, including the acquisition or divestment of any reported interest.

Guidance on the Confidential Declaration Process

Office employees also have the responsibilities and duties set out as follows:

  • to carry out their official duties, to arrange their private affairs in a manner that will prevent real, apparent, or potential conflicts of interest from arising;
  • to take all possible steps to recognize, prevent, report, and resolve any real, apparent, or potential conflicts of interest;
  • should any conflicts arise, to resolve them in favour of the public interest;
  • not to have private interests, other than those permitted pursuant to these measures, which would be affected particularly or significantly by government actions in which they participate;
  • not to solicit or accept transfers of economic benefit;
  • not to place themselves in a position where they are under an obligation to any person who might benefit from special consideration or favour on their part or seek in any way to gain special treatment from them;
  • not to assist private entities or persons in their dealings with the government where this would result in preferential treatment to the entities or persons;
  • not to knowingly take advantage of, or benefit from, information that is obtained in the course of their official duties and that is not generally available to the public;
  • not to use directly or indirectly, or allow the use of, government property of any kind, including property leased to the government, for anything other than officially approved activities;
  • to maintain the impartiality of the Office and not engage in any outside activity that impairs or could be seen to impair their ability to perform their duties in an objective and impartial manner; and
  • to refrain from public statements about the Office and the Government of Canada that could impair or appear to impair the objectivity and impartiality of the Office employee or the Office.

It is impossible to foresee every situation that could give rise to a real, apparent, or potential conflict. The Office must carefully consider actions to be taken in situations where there could be a reasonable perception that an Office employee’s interest could improperly influence the performance of official duties—whether or not this is in fact the case. Other potential conflict-of-interest situations may also be of concern. For example employees may have private interests that may not interfere with their current work but could interfere with their official duties in the future.

When in doubt, advice should be sought from supervisor(s), the Internal Specialist on Values and Ethics, Legal Services, the Senior Officer for Disclosure, or an Assistant Auditor General.

Outside employment or activities

Employees’ primary professional responsibility is to the Office. This responsibility takes precedence over any other working relationships.

Office employees may engage in employment outside the Office and take part in outside activities, when the employment or activities are not likely to give rise to a real, apparent, or potential conflict of interest or in any way undermine the Office’s neutrality, objectivity, or impartiality. The following provides general guidance:

  • Secondary employment that interferes with an employee’s duties to the Office should be avoided.
  • Outside work endeavours should be undertaken only if they leave employees fully capable of carrying out their duties at the Office.
  • Information gained through association with the Office should not be used in secondary employment.

Any unauthorized outside work that is performed during the hours worked for the Office is improper and constitutes grounds for dismissal. Even if outside work is authorized to be performed during office hours (for example, work for a professional association or teaching), employees are not entitled to receive double remuneration for services rendered.

Where outside employment or activities might subject Office employees to demands that are incompatible with their official duties, or cast doubt on their ability to perform their duties in a completely objective manner, they shall submit a Confidential Report to the Office. The AAG most directly affected may require that the outside activities be curtailed, modified, or terminated if it is determined that real, apparent, or potential conflict of interest exists.

Employees wishing to undertake outside activities that may give rise to real, apparent, or potential conflict of interest must receive written approval from their supervisor in consultation with Legal Services.

Secondary employment relating to government activities or officials, either directly or on behalf of an external third party contracting with government, is considered to give rise to a conflict of interest, unless the contrary can be established by the employee.

The Supreme Court of Canada has ruled that a total prohibition against public servants working for or against a political party is a violation of the right to freedom of expression as set out in the Charter of Rights and Freedoms. However, the Court also recognized the importance of maintaining the political neutrality of the Public Service. The consequences for public servants have been addressed in Part 7 of the Public Service Employment Act. In keeping with those provisions, it is important for employees of the Office to consider the impact of the type of political activity that they may wish to undertake on their ability to carry out, and be seen to carry out, the duties of their employment in an impartial manner. The crucial element in determining the appropriateness of an employee’s political activities is whether the employment duties contain the scope for the exercise of any discretion that could be, or appear to be, influenced by political considerations. The more senior the level of the employee, the greater the need for care and prudence with regard to political activities.

Leave without pay to participate as a candidate in municipal, provincial, or federal elections is subject to the specific approval of the Auditor General. Obtaining permission to carry out other types of political activities is also recommended. Leave without pay or permission to carry out other political activities will be granted only where it is considered that the Office would not be inconvenienced or impaired by the candidacy or activity. The Office will also consider whether the employee occupies a position that the Office considers to be sensitive to political activity. As a general rule, however, every employee has the right to engage in activity in support of political candidates and parties, as long as such activity does not call into question the employee’s ability to perform effectively and in an impartial manner.

Avoidance of preferential treatment

Office employees are responsible for demonstrating objectivity and impartiality in their duties and in their decision-making, whether related to a staffing process, contractual awards to external parties, or any other exercise of responsibility.

As a general rule, granting preferential treatment or advantages to family, friends, or any other person or entity is considered to give rise to a conflict of interest unless the contrary can be established. Providing information that is publicly accessible is not considered preferential treatment.

Gifts, hospitality, and other benefits

Office employees must not accept or solicit any gifts, hospitality, or other benefits that may have a real or apparent influence on their objectivity in carrying out their official duties, or that may place them or the Office under obligation to the donor. This may include free or discounted admission to sporting and cultural events, travel, or conferences arising out of an actual or potential business relationship directly related to the employee’s official duties. This includes offers from an audit entity or a consultant or contractor.

The acceptance of gifts, hospitality, and other benefits is permissible if offers

  • are infrequent and of minimal or nominal value (for example, low-cost promotional objects, inexpensive meals, and souvenirs with no cash value);
  • arise from activities or events related to the official duties of the employee concerned;
  • are within the normal standards of courtesy, hospitality, or protocol; and
  • do not compromise or appear to compromise in any way the integrity of the employee concerned or of the Office.

In some situations, it may be impossible to decline gifts, hospitality, and other benefits that do not meet the guidelines set out above (for example, gifts from dignitaries). If it is believed that there is sufficient benefit to the Office to warrant acceptance of certain types of gifts or hospitality, an employee must seek specific written direction from his or her AAG. The AAG may consult with Human Resources and Legal Services and will then notify the employee in writing whether the gifts, hospitality, and other benefits are to be declined or retained by the Office, donated to charity, disposed of, or retained by the employee concerned. With the exception of fundraising for charitable organizations, Office employees may not solicit 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.

When fundraising for charitable organizations, Office employees should ensure that they have prior written authorization from their AAG to solicit donations, prizes, or contributions in kind from external organizations or individuals. Authorization will not be granted where there is a real, apparent, or potential conflict of interest or a perception of obligation to the donor.

This Code is consistent with paragraph 121(1)(c) of the Criminal Code of Canada; if employees have complied with these provisions, they are entitled to rely on the consent of the Auditor General.    

Post-employment measures

Without unduly restricting their ability to seek other employment, employees should undertake to minimize the possibility of real, apparent, or potential conflicts of interest between their subsequent employment and their most recent responsibilities within the Office.

Employees should not allow themselves to be influenced in their official functions by plans or offers of outside employment. If an offer of employment might give rise to a conflict of interest situation, employees should disclose their intentions regarding job offers or future employment before leaving employment. They should discuss the potential conflicts with their principal or service leader or, where appropriate, their AAG.

Employees who leave employment with the Office are reminded that they have sworn oaths of confidentiality and that they remain bound by those oaths in relation to information acquired in the course of their employment with the Office.

In addition, employees in categories DAG, AAG, principal, and director must disclose to their supervisor (AAG, DAG, or the AG) all offers of employment that could place them in a real, apparent, or potential conflict of interest situation. They must also disclose immediately the acceptance of any such offer.

These employees shall not, within a period of one year after leaving the Office

  • make representations for, or on behalf of, persons to any department or organization with which they personally, or through their subordinates, had significant official dealings during the period of one year immediately prior to the termination of their service; or
  • give advice to their clients using information that is not readily available to the public concerning the programs or policies of the departments or organizations with which they had a direct and substantial relationship.

The Auditor General has the authority to reduce or waive the post-employment limitation period for an employee or former employee. Such a decision should take into consideration the following:

  • the circumstances under which the termination of service occurred;
  • the general employment prospects of the employee or former employee;
  • the significance to the government of information possessed by the employee or former employee by virtue of that individual’s position in the Office;
  • the desirability of a rapid transfer of the employee’s or former employee’s knowledge and skills from the government to private, other governmental, or non-governmental sectors;
  • the degree to which the new employer might gain unfair commercial or private advantage by hiring the employee or former employee; 
  • the authority and influence the employee possessed while in the Office; and
  • any other consideration at the discretion of the Auditor General.

Lobbying Act restrictions on post-employment apply to public office holders, which include those management employees in categories DAG (if any), AAG, CESD, senior principal, and service leader. These employees are prohibited from accepting any position as a lobbyist within the meaning of the Lobbying Act within five years of leaving or retiring from their positions with the Office. For these employees, the ability to engage in certain post-employment activities set out above, where these activities constitute lobbying, may be restricted for five years, rather than one year.