Code of conduct The City of Edmonton

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code of
conduct
The City of Edmonton

Effective February 2021
CONTENTS
Why Have a Code of Conduct?                  3

How Does the Code Affect Me?                 3

Ethical Questions                            3

Disclosure and
Compliance Obligations                       5

Role of Leaders                              5

Guiding Principles and Themes                6

Part 1: Employee Behaviour                   7
Personal Conduct                             8
Respectful Workplace                         9

Part 2: City Assets                         10
City Time and Assets                        11
Access to Information
and Protection of Privacy                   13

Part 3: Conflicts of Interest               16
Gifts and Entertainment                     18
Personal Gain, Benefit,
or Favouritism                              20
Other Employment                            21
Appearances Before Council                  22
Political Activity                          23
Other Reference Documents                   24

Program Impacted: Employee Experience and Safety
Approved by: City Manager, Andre Corbould
Date of Approval: February 2021
Approval History: June 2018
Next Scheduled Review: 2024
code of conduct

Why Have a                                         the foundation upon which this organization
                                                   is built. This Code of Conduct is simply a
Code of Conduct?                                   reminder of the principles of conduct the
Our Employee Code of Conduct explains              City has always embraced. In addition to
the expected rules of behaviour as                 this Code of Conduct, all City employees
employees of the City. It states our values,       are governed by and required to follow all
provides guidance, and recommends action           City policies.
so all employees know exactly what is
expected of them.
                                                   How Does the
The Code of Conduct creates an                     Code Affect Me?
environment that encourages a specific
                                                   The City of Edmonton acknowledges it
standard of behaviour, supports our
                                                   is only through the commitment of our
Cultural Commitments and Leadership
                                                   employees that we are able to deliver quality
Competencies, lessens confusion, and
                                                   service and maintain public trust. As our
promotes equality and respect within
                                                   most valued asset, City employees must
the workplace.
                                                   be above reproach in their professional
Harassment and discrimination in any form          dealings and must demonstrate the highest
is not acceptable in the City workplace.           standards of behaviour. Being accountable
Every employee has the right to a respectful       means we are trusted and empowered
workplace, free of harassment and                  to embrace our responsibility for our
discrimination.                                    actions, decisions, and behaviours. This is
                                                   because working together, aligned with
As an employee, it’s your responsibility           Council’s vision, we enable a better life for
to bring attention to any concerning               all Edmontonians. We are accountable to
behaviours without fear of threat,                 the City, City Council, and the citizens of
retaliation, discrimination or discipline. If      Edmonton. It is with this in mind that every
you aren’t able to address the unacceptable        City employee is expected to be aware of,
behaviour with your coworkers, ask your            and comply with, the Code of Conduct,
supervisor for help. If you are not able to        Respectful Workplace Policy, and other
do this consider contacting the Labour             policies that govern employee behaviour.
Relations Consultant for your area or the
Safe Disclosure Office.
                                                   Ethical Questions
When all employees are treated equitably           The Code of Conduct can’t outline every
– with dignity, respect, and trust – they          example of inappropriate employee
feel valued and are more likely to perform         behaviour or every situation that might
well and to enjoy their jobs. This, in turn,       create an actual, potential, or perceived
enhances our effectiveness as City                 conflict of interest. Each of us must
employees, and promotes public confidence          understand and apply basic ethical standards
in the integrity of City services.                 to ensure our behaviours and actions do not
                                                   violate an employee’s basic duty of loyalty
The Code of Conduct is critical to both our
                                                   to the City. Employees are also obligated
success and our reputation. The information
                                                   to adhere to the City’s existing policies and
in this Code of Conduct is not new to you; it is

                                                                                              3
code of conduct

procedures, including commitments to             issue is too sensitive to discuss with a
environmental stewardship. Rest assured          peer, feel free to access the following City
that all of us, at some point, are faced         resources for advice:
with ethical dilemmas and struggle to find
                                                 + Your direct supervisor
an answer to the question, “What is the
right thing to do?” When in doubt, talk          + Your Director or Branch Manager
to your supervisor(s), and ask yourself          + Any of the Deputy City Managers
these questions:
                                                 + City Manager
+ Will this result in a personal
    gain or benefit?                             + City Auditor
+ Could this action lead to fraud?               + Employee Services representatives
+ Could an outside person, co-worker             + Labour Relations
    or the media perceive this action            + City Chaplain
    as unethical?
                                                 + Corporate Access and Privacy
+ Will I owe somebody something as a                (CAP) Office
    result of this action?
                                                 + Corporate Security
+ Was this gift/action intended to
                                                 + Employee and Family Assistance
    influence my decision?
                                                    Program Provider
+ Would I hesitate to take this action or to
                                                 + Code of Conduct/Conflict of
    allow my employees to take this action
                                                    Interest Specialist
    in my own company?
+ Could this action put someone’s health         Employees always have the option of
    and safety at risk?                          speaking to any of the supervisors,
                                                 managers, or leaders in the organization
+ Could my comments on social media or           to get advice and guidance on the Code
    in a public forum be considered negative,
                                                 of Conduct. Find someone you are
    derogatory, discriminatory or be taken
                                                 comfortable speaking with and get the
    as a criticism of the City of Edmonton or
                                                 information you need.
    a fellow City employee or reflect poorly
    on the City of Edmonton?
                                                 Professional Codes of Conduct
If you answered “yes” to any of these            Employees with professional affiliations –
questions, you may have an ethical               accountants, lawyers, engineers, auditors,
dilemma. Change your actions or seek             safety officers, and social workers – may be
advice. If you’re still not sure, ASK again      subject to more than one code of conduct.
and keep ASKING until you get an answer.         If a situation arises that may cause conflict
A simple rule may help - “if in doubt, don’t.”   or confusion between the applicable codes,
If you can’t arrive at an answer or if your      consult with your supervisor. If additional
                                                 support is required, please consult with one
                                                 of the City resources listed above.

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code of conduct

Disclosure and                                   or discrimination, or other respectful
                                                 workplace issues, should be reported to
Compliance Obligations                           your supervisor, or if you are not able,
Each employee must read and understand           contact the Safe Disclosure Office.
the Code of Conduct and complete the
mandatory training on the Learning               Whenever something doesn’t seem right, the
Management System (LMS).                         most important thing is to report it through
                                                 the avenue you feel most comfortable.
If you think you may be in violation of the      Recipients of reports that are more
Code of Conduct, address the situation and       appropriately handled by another area have
make full and prompt disclosure to your          an obligation to ensure that it is redirected
direct supervisor. In addition, if you have an   in a timely manner. For details regarding
actual, potential, or perceived conflict of      protections for whistleblowers, please see
interest you must disclose that to your          the Whistleblower Protection Procedure.
Branch Manager and the Code of Conduct/
Conflict of Interest Specialist using the        Anyone who knowingly makes a false
Conflict of Interest Disclosure Form. Based      accusation about non-compliance, and
in the Legal Services Branch, the Code of        anyone found to be in violation of the Code
Conduct/Conflict of Interest Specialist          of Conduct may be subject to disciplinary
receives and retains disclosure forms and        action, up to and including dismissal.
provides advice on addressing conflicts of       Discipline of City Employees Policy.
interest. More detail on conflicts of interest
is provided in Part 3.                           Role of Leaders
Any suspected non-compliance with the            Leaders set the tone and expectations
Code of Conduct by another employee              across our organization. In addition to
must also be promptly reported. Reports          adhering to the Code of Conduct as
should be made to your direct supervisor,        employees, leaders (which includes all
and in situations where that is not possible     supervisors, directors, managers, and
or comfortable, employees may report             Deputy City Managers) have an additional
non-compliance to their Branch Manager           obligation to promote awareness of the
or Labour Relations. Employees also have         Code of Conduct and be available to
the option of reporting any non-                 provide guidance regarding behaviour.
compliance with the Code of Conduct
through the City’s Fraud and Misconduct          Any leader that receives a complaint or
Hotline. Reports made through the hotline        becomes aware of a potential violation
can be made anonymously.                         of the Code of Conduct must report it to
                                                 the appropriate City resource and take
Any employee that suspects a fraud may           appropriate action based on the advice
have occurred within the City must report        provided to them. Leaders must not
the incident using the process prescribed in     independently investigate complaints or
the Fraud Reporting and Investigation            take disciplinary or retaliatory action in
Procedure. Concerns regarding                    any circumstance.
harassment

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code of conduct

Potential violations should be reported to:       Guiding Principles
+ Corporate Security (criminal or                 and Themes
    security threats)
                                                  There are nine key guiding principles,
+ Corporate Access and Privacy Office             reflected in three themes, that guide
    (privacy concerns)                            different aspects of our conduct as City
                                                  employees. They are:
+ Labour Relations (any misconduct)
+ City Auditor (any potential fraud)              Employee Behaviour
+ Code of Conduct/Conflict of Interest            + Personal Conduct
    Specialist, Legal Services (conflicts
    of interest)                                  + Respectful Workplace
+ Safe Disclosure Office                          City Assets
    (respectful workplace)
                                                  + City Time and Assets
+ Workplace Safety and Employee
    Health (safety)                               + Access to Information and
                                                     Protection of Privacy
When in doubt, report wherever you feel
most comfortable. Each of the areas listed        Conflicts of Interest
above has a responsibility to redirect            + Gifts and Entertainment
complaints to a more appropriate area
if necessary.                                     + Personal Gain, Benefit, or Favouritism
                                                  + Other Employment
If you as a leader become aware of a conflict
of interest that has not been disclosed, ensure   + Political Activity
the employee is aware of their reporting          + Appearances Before Council
obligations and assist them to complete the
Conflict of Interest Disclosure form, with
input from the Code of Conduct/Conflict of
Interest Specialist if needed. Completed forms
must be submitted to the employee’s Branch
Manager to ensure awareness of the conflict
and support for the proposed mitigations,
and then forwarded to the Code of Conduct/
Conflict of Interest Specialist for retention.

Leaders involved in onboarding employees
moving from one City position to another
should ask employees about disclosure
forms provided in their previous role and
ensure copies are provided to their current
Branch Manager and support the employee
to implement any required mitigations in
relation to their new role.

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1
EMPLOYEE
BEHAVIOUR
Personal Conduct
Respectful Workplace
code of conduct

Personal Conduct                               Frequently Asked Questions

Guiding Principle: We will perform our         Q Do I have to follow the Code of
duties with honesty and integrity in              Conduct when I’m off duty but
                                                  still in my City uniform?
a manner that is helpful, responsive,
and courteous.                                 A Yes. When you are in uniform, the public
                                                  identifies you as a City employee and
What Does This Mean?                              may assume you are performing
                                                  City duties.
Employees will do their jobs to the best
of their ability, conduct themselves
                                               Q Can I use social media venues such as
appropriately and will be considerate
                                                  Twitter, Facebook, Instagram or my
and helpful to all people, both internally
                                                  personal blog to voice my opinions
and externally.
                                                  about Council decisions, fellow
                                                  employees or my workplace?
Why is This Important?
                                               A Your personal social media accounts
It takes the effort of each and every
                                                  are part of your right to expression.
employee to make Edmonton a great place
                                                  However, if it is reasonable that you
to live, learn, work, and play. Employees
                                                  could be identified as a City employee,
must maintain awareness of their
                                                  your comments on social media must
behaviours and treat others as they wish
                                                  accurately reflect the decisions of Council
to be treated.
                                                  and Administration and must not weigh
The public often sees us as ambassadors           in on the opinions or political positions
for the City and this is reflected in the         of elected officials. Posts to your private
Cultural Commitment - Accountable. We             accounts must not undermine City
must be seen to be taking care of the City’s      Council or Administration’s objectives,
assets and its citizens. As such, it is our       the City’s reputation or relationships
responsibility to care for the community          with its stakeholders. Comments
and to make sure Edmontonians get the             should not discriminate, harass, or
best value for their tax dollars. This means      demonstrate disrespect toward any
working to maintain the public’s confidence       person. Engagement with members of
by acting courteously and responsibly             the public, in any forum, that encourages
and by providing the best possible                respectful dialogue on relevant municipal
level of service.                                 issues is not a breach of the Code of
                                                  Conduct provided that it is factual,
Things To Do                                      appropriate, and does not conflict with
                                                  Council direction and the City’s other
Practice professional employee
                                                  obligations, such as protecting privacy
behaviour that contributes to a respectful
                                                  and maintaining confidentiality and a
workplace, and that models our Cultural
                                                  respectful workplace. Inappropriate
Commitments of being Safe, Helpful,
                                                  content posted on personal social media
Accountable, Integrated and Excellent. Stay
                                                  may impact your employment with the
in the Green Zone when interacting with
                                                  City whether or not it was posted from a
colleagues and the public.
                                                  City device or during work hours.

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code of conduct

Q In my job, I’m in regular contact with       Respectful Workplace
   frustrated and upset people. How do I
   deal with their behaviours?                 Guiding Principle: We will all do our part
                                               to ensure our workplaces are free from
A Those that we serve can occasionally         harassment and discrimination, and our
   express anger and frustration and that
                                               fellow employees and those whom we
   is understandable. Try using various
                                               serve are treated fairly.
   techniques to engage the individual and
   defuse the situation. Let the person        The Respectful Workplace Administrative
   know you want to help and advise            Procedure outlines how respectful
   that finding a respectful approach to       workplace concerns will be addressed.
   the conversation is important. If the
   behaviour continues despite your best       If you have a respectful workplace concern,
   efforts, exit the situation or escalate     you are encouraged to talk to the person
   to a supervisor or support person. If       with whom you have a concern, or with your
   you encounter extreme aggression            supervisor. If you aren’t able to speak with
   or do not feel safe, know that you can      the individual or your supervisor about your
   exit or escalate a situation. Know your     concern, you can make an appointment with
   area’s response plan and when to call       the Safe Disclosure Office.
   Corporate Security.

Q Can I stop for a beer or wine on my
   way home from work if I’m wearing
   my City uniform?

A No. Although you are on your own
   time, your uniform leads people to
   believe otherwise.

Q Can I record conversations or
   meetings at work?

A If you wish to record a conversation
   or meeting, advise participants of the
   purpose for recording and explain how
   you will use the recording. Covert or
   surreptitious recording is not permitted
   and if a participant objects, approval
   from labour relations or an appropriate
   supervisor should be obtained in
   advance of the recording. Recording
   members of the public for personal or
   outside of City-approved purposes is
   not permitted.

                                              Code of Conduct                            9
2
CITY ASSETS
City Time and Assets
Access to Information
and Protection of Privacy
code of conduct

City Time and Assets                            Things To Do

Guiding Principle: We will safeguard
                                                + Respect City assets and take proper
                                                   care of them, whether using them at a
and protect City assets, and only
                                                   City facility or at home for City purposes
use information collected by the City
for purposes consistent with the                + Use City assets only for City work
use for which it was collected. We              + Reimburse the City promptly for any
will not use any City asset, including             approved personal use that incurs costs
e-mail, internet services, or any                  (long distance calls, photocopying)
other electronic communication                  + Obtain approval for exemptions
devices, if the use could be offensive
or inappropriate.                               Things Not To Do
Employees must devote themselves                + Take home City assets for personal use
exclusively to the performance of their            without prior approval
employment duties during paid working           + Use a City vehicle for personal business
hours. We will use and permit the use
of City time and assets only for the
                                                + Install personal software or connect
                                                   personal hardware to City computers
performance of City duties or as approved
                                                   without permission from your supervisor
by our supervisors.
                                                + Download software on City equipment
What Does This Mean?                               without prior approval
City employees are required to care for         + Use City assets for storing or sharing
City assets which includes all property,           non-work related or personal
equipment, software, information, and              information, or grant personal accounts
time. City assets may only be used                 access to City assets
for City purposes or as approved by
                                                + Abuse email, Internet connections, or
your supervisor.
                                                   any other electronic communication
                                                   devices that could be used for content
Why is this important?                             deemed as offensive or harassing,
The City, like any organization, cannot            such as hate material, slurs based on
afford to waste time, money, or resources.         someone’s identity (e.g., race, ethnicity,
We serve all the citizens of Edmonton and          gender, or sexual orientation), gambling
our work is paid for by their tax dollars. To      and sexually explicit material.
do our jobs properly, we need to have all
                                                + Accessing, creating, viewing, sending or
resources available at all times. Whether
                                                   downloading of inappropriate material
the asset in question is work time, a City
                                                   will be dealt with severely.
vehicle, or a computer, it must be ready and
available to do the assigned task.              Any violation may result in discipline up to
                                                and including termination of employment.

                                                                                               11
code of conduct

Tips to Secure and                             Frequently Asked Questions
Protect City Assets                            Q Can I photocopy my son’s hockey
Security is everyone’s business and we all         schedule for him and his teammates?
have a role to play.
                                               A One or two copies is not an abuse
+ Keep your ID card secure and visible.            of City assets. Multiple copies, or
+ Safely engage strangers and visitors             repeated use of City equipment, require
     not wearing ID cards.                         supervisor approval and reimbursement
                                                   to the City.
+ Use customer service skills to engage
     unknown persons, such as “How may
                                               Q Can I help myself to things the office is
     I help you?” or “Let me take you to
                                                   throwing away or declaring surplus?
     that person.”
                                               A No. Articles in the garbage are still
+ Prevent unauthorized access.
                                                   considered City assets. If you are
+ Escort visitors to and from entry points.        interested in purchasing an item that has
+ Do not prop secured doors open.                  been declared surplus, contact Corporate
                                                   Procurement and Supply Services.
+ Protect and secure all sensitive
     information. Devices and records
                                               Q Can I use the Internet at work to
     should never be left unattended.
                                                   plan my vacation and book my
+ Do not download City information to              airline tickets?
     your personal phone or other device, or
                                               A Yes, provided you do it on your own time
     grant access to your City accounts to
                                                   (i.e. lunch, coffee breaks), there are no
     external accounts.
                                                   costs to the City, and your activity does
+ Lock filing cabinets, portable                   not place City computer systems at risk.
     devices, documents and computers
     before you leave.                         Q Is it appropriate to sell chocolates
+ Do not respond to spam or                        or raffle tickets or collect money for
     phishing attempts.                            charitable associations at my work site
                                                   during normal working hours?
+ Have a good, strong password.
                                               A This is acceptable, subject to approval
+ Report crimes in progress to 911.                by your immediate supervisor or any
+ If after the fact, call EPS at                   branch specific procedures.
     780-423-4567 and Corporate
     Security at 780-496-8888.                 Q Can I access City assets for occasional
                                                   personal use? What about infrequent
                                                   phone calls? Can I call my child’s daycare
                                                   or make a medical appointment?

                                               A Yes. Infrequent and incidental use of
                                                   City assets for personal reasons is
                                                   allowed as long as there is no negative

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code of conduct

    impact on your performance, no abuse        Access to Information
    of paid work time or no added cost to
                                                and Protection of Privacy
    the City. This includes telephone and
    cellular phone use.                         Guiding Principle: We will respect
                                                our legal and ethical obligation to
Q I have to take a City vehicle home at         comply with the provincial Freedom of
    night. If the grocery store is not out of   Information and Protection of Privacy
    my way, can I stop in the City vehicle?     (FOIP) Act as a shared responsibility
A No. Employees who are provided with           of all City employees. Every employee
    a vehicle for City work are expected        has a duty to respect the privacy of
    to use the shortest route between           Edmontonians and fellow employees,
    their assigned work location and            to secure personal information, and
    their residence, without stopping for       support access to information.
    private purposes.
                                                What Does This Mean?
Q Can I do personal work at my
                                                Personal information (PI) includes, but is
    workstation during lunch hour?
                                                not limited to:
A Incidental use of your work station is        + Name, home address, home
    permissible as long as you are doing the       telephone number
    work on your own time and there is no
    cost to the City.                           + Race, ethnic origin
                                                + Age, sex, marital or family status
Q What should I do if I receive chain letters
                                                + Medical history
    or offensive jokes and pictures at my
    work email address?                         + Employment and financial history
A Delete them immediately and tell the          + Personal opinions about other
    sender to stop sending them to your            identifiable individuals, such as
    City address. You should also consider         an employee’s opinion about
    informing your supervisor depending on         another employee
    the frequency or content of the emails.
                                                The FOIP Act governs the purposes
    We are all responsible for ensuring
                                                for which PI may be collected, used, or
    the City’s email and systems are
                                                disclosed. PI is collected when it is gathered
    used appropriately.
                                                from an individual (such as signing someone
                                                up for a City service), PI is used when
Q What should I do if I see an employee
                                                employees access PI in a City system, and
    siphoning gas from a City vehicle?
                                                PI is disclosed when City employees send or
A Report the incident to your supervisor        transmit PI to someone who does not work
    or to Corporate Security.                   for the City of Edmonton (such as disclosure
                                                to the Edmonton Police Service).

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code of conduct

Any individual has the right to make an       Frequently Asked Questions
access to information request for any City
                                              Q One of my co-workers applied for a
record in any format. Employees have an
                                                 job in my unit. I don’t think that my
obligation to maintain records in order
                                                 co-worker will be good at the job.
to support access to information, and to
                                                 Can I tell my boss?
provide records when they are subject
to a request.                                 A No. Someone’s application for a position
                                                 and the processing of recruitment
Why is This Important?                           is confidential. You may only share
                                                 information about your co-worker if
Information access and privacy is a means
                                                 your co-worker or the hiring manager
of ensuring the continued preservation
                                                 asks you for a reference.
of openness, fairness, transparency and
respect for the privacy of Edmontonians and
City employees.                               Q What should be the default access
                                                 permission for a document containing
                                                 personal information in Google?
Things To Do
+ Keep personal information secure.           A Records containing personal information
                                                 should be shared only with those who
+ Collect, use and disclose personal             need access to the document
     information only for work purposes.
+ Access City systems only for                Q I’ve been asked to search for records
     work purposes.                              for a FOIP request. The records are
                                                 potentially embarrassing to me. Do
+ Search for and provide responsive
                                                 I have to give them to the CAP Office?
     records to requests for access to
     information.                             A Yes, you are required to provide records
+ Verify authority for disclosure prior to       to the CAP Office. The CAP Office
     disclosure of personal information.         reviews all records before they are
                                                 released, and it is an offence under the
+ Contact the Corporate Access and               FOIP Act to interfere with the processing
     Privacy (CAP) Office for assistance         of FOIP requests.
     on your FOIP responsibilities on how
     to use, collect and disclose personal    Q What should I consider about privacy
     information at foip@edmonton.ca or          when I’m conducting a survey?
     780-496-5222.
                                              A Only collect personal information
                                                 if necessary. Consider that even
                                                 if a name isn’t collected, a survey
                                                 may contain enough information to
                                                 identify someone.

                                                 You must notify those completing the
                                                 survey of the purpose of performing the
                                                 survey, and how the data will be used
                                                 and potentially disclosed.

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code of conduct

   Collection of data must be used to
   support a program or service of the City.
   Curiosity is not a reason to collect data.

   Survey data can only be used for the
   purpose for which it was collected.

   Survey data cannot be kept
   in perpetuity.

   If data is collected via a Google form,
   access to the data must be controlled.

Q I made a complaint about my
   neighbour’s dog. Can I look up the
   status of the complaint in POSSE?

A No. You have been provided access to
   POSSE for work purposes. You are not
   permitted to access POSSE for any
   reason other than work purposes.

Q I handle the Human Resources files
   for my office and discovered my
   co‑worker’s 40th birthday is coming
   up. Can I plan a surprise party?

A No. If you found out about the birthday
   through City records, the information
   is considered confidential and cannot
   be shared with colleagues or used to
   plan a party.

Q A staff member has gone on medical
   leave. Can I send out an email to notify
   the team about this?

A You may communicate that staff
   members are away from work, but not
   to identify why they are away.

                                                             15
3
CONFLICTS
OF INTEREST
Gifts and Entertainment
Personal Gain, Benefit,
or Favouritism
Other Employment
Appearances Before Council
Political Activity
code of conduct

Conflicts of Interest                              The existence of a potential or perceived
                                                   conflict is not a breach of this Code of
Guiding Principle: We will avoid or                Conduct as long as it is disclosed and
mitigate all conflicts of interest.                mitigation measures are implemented
                                                   and followed. In some cases, perceived
What Does This Mean?                               conflicts can be a good thing and
A conflict of interest involves a potential,       should be encouraged - for example, an
perceived, or actual conflict between              employee that actively volunteers with
employees’ duties and their private                a non-profit organization must disclose
interests. It may occur in a situation where       a conflict of interest if that organization
an employee has private interests that could       is applying for City funding. Provided
improperly influence the performance of            that the employee does not work in the
their official duties and responsibilities or      area responsible for funding decisions
where an employee uses their office for            and does not take any steps to attempt
personal gain or in personal circumstances.        to influence the funding decision, this
Generally, conflicts of interest arise in one      would be a perceived conflict - and a great
of five situations: gifts offered or received      example of how we as employees can
in the course of employment; using City            improve the community around us. By
employment for personal gain, benefit, or          having disclosed the perceived conflict,
favoritism; other employment that may              if a concern is raised in the future the
conflict with City employment; personal            City and the employee can take comfort
political activity; or personal appearances        knowing that the situation was disclosed
before Council.                                    and documented. The existence of a conflict
                                                   will never automatically be considered to
Conflicts of interest may be actual, potential,    be a bad thing - only a failure to disclose
or perceived:                                      the existence of a conflict or implement
                                                   appropriate mitigations will be considered
Actual conflict: a situation in which an
                                                   a violation of this Code of Conduct.
employee’s personal or private interests
improperly influence the performance of            The appropriate mitigation measures
official duties and responsibilities or where      for individual conflicts will vary based on
a position is used for personal gain or in         the facts, and may include steps such as
personal circumstances.                            removing yourself from certain projects
                                                   or situations, or having a peer review
Potential conflict: a situation where an
                                                   work before approval. If you need support
actual conflict could reasonably exist
                                                   developing appropriate mitigations you can
in the future if mitigation strategies are
                                                   contact the Code of Conduct/Conflict of
not followed.
                                                   Interest Specialist.
Perceived conflict: a situation where no
                                                   Actual conflicts, however, are a serious
actual conflict exists, however, the situation
                                                   concern and may result in discipline. Any
could be perceived by a reasonable observer
                                                   employee that becomes aware of an actual
to be a conflict, whether or not it is the case.
                                                   conflict must disclose it as outlined under
                                                   Disclosure and Compliance Obligations.

                                                                                             17
code of conduct

Things To Do                                        Gifts and Entertainment
If you believe you have a conflict, whether it
                                                    Guiding Principle: We will not accept
be actual, potential, or perceived, you must
                                                    or provide any gift, benefit, or favour
complete the Conflict of Interest Disclosure
Form. Completed forms must be submitted
                                                    in exchange for special consideration
to your Branch Manager to ensure                    or influence, and we will mitigate
awareness of the conflict and support               any perceptions that may arise
for the proposed mitigations, and then              from courtesy or professional and
forwarded to the Code of Conduct/Conflict           community relationships.
of Interest Specialist for retention. Branch
Managers disclosing conflicts of interest           What Does This Mean?
must submit completed forms to their                Employees must not give or receive gifts in
Deputy City Manager before forwarding to            exchange for actual special consideration
the Code of Conduct/Conflict of Interest            or favours, and if a gift might be perceived
Specialist. All disclosing employees will           as this, it must be disclosed and align with
receive a copy of their completed form for          City guidelines.
their records. If you change positions within
the City after disclosing a conflict of interest,
                                                    Why is This Important?
you must provide a copy of the completed
form to your new Branch Manager and                 Although most gifts come with no strings
continue to implement mitigations agreed            attached, there is always the chance that
to in the form.                                     something is expected or perceived to be
                                                    expected in return.
If new information arises in relation to a
declared conflict, you must update the form         Things To Do
and resubmit the completed form to your
                                                    + Before accepting any gift or gratuity,
Branch Manager and the Code of Conduct/
                                                       consider how the acceptance of the gift
Conflict of Interest Specialist.
                                                       would be perceived by the media, Council
In addition to the steps outlined in this Part,        and a company’s competitors.
employees engaged in procurement must               + Refuse all cash tips or cash gifts.
also comply with other conflict mitigations,
                                                    + Decline gifts that are intended as an
including the Conflict of Interest After City
                                                       exchange for a favour.
Employment Procedure and Conflict of
Interest of Employees Participating in City         + Decline gifts from potential vendors or
Procurements Procedure.                                interested parties during or in anticipation
                                                       of a purchasing or tendering process that
                                                       you are involved in.
                                                    + Decline the gift or ask your supervisor if
                                                       you are unsure.
                                                    + Disclose appropriate gifts in accordance
                                                       with City guidelines.

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code of conduct

Frequently Asked Questions                     Q The City paid for me to attend a
                                                  conference and I won a door prize.
Q The City is in the process of awarding
                                                  Can I accept it?
    a contract and I am involved in the
    decision process. One of the bidders has   A You can accept the door prize but if the
    offered to take me to an Oilers’ game.        prize is of significant value, you should
    Can I accept the invitation?                  advise your supervisor and disclose
                                                  it in accordance with City guidelines.
A No. This is an actual conflict of interest
                                                  You are not permitted to accept a cash
    as the bidder could be given special
                                                  honorarium. Items such as gift cards
    consideration or favours in return for
                                                  or other cash rewards should not be
    the ticket(s).
                                                  accepted but may be received and used
                                                  for the benefit of a department, branch
Q I’m a collector in Waste Management.
                                                  or group of employees, if the amount
    Some of the seniors on my route like to
                                                  is reasonable and would be perceived
    give me a cash tip at Christmas. I don’t
                                                  as acceptable by members of the
    want to be impolite by rejecting what is
                                                  general public.
    a kind and sincere gesture. How should
    I respond? Can I accept any gifts?
                                               Q I am helping to organize my department’s
A Politely explain that you appreciate            annual golf tournament. Can I solicit local
    the gesture but the City already              merchants for prizes? Can I solicit other
    compensates you. It is unacceptable           departments for prizes?
    to accept cash, but civic employees
                                               A Yes, with permission from your
    may accept:
                                                  Deputy City Manager. You can solicit
    + Small holiday gifts showing                 local merchants as long as you do not
       appreciation (cards, cookies,              use a City vendor list. You can also
       chocolates)                                approach other City departments for
    + Advertising material (calendars,            prizes; however, please be aware the
       scratch pads, disposable pens,             departments are the stewards of the
       t-shirts, caps)                            assets within their control and your
                                                  request will be considered in the same
    + Corporate discounts that are                way as one from an external person
       available to all City employees            or organization.
    + Protocol items (symbolic or
       ceremonial gifts, such as pens
       or ornamental objects)

Q I have been asked to speak at a
    conference and the organizers offered
    an honorarium. Can I accept it?

A No. As you are representing the City and
    are paid a salary, you may accept free
    attendance to the conference or a small
    token gift, but not an honorarium.

                                                                                           19
code of conduct

Personal Gain, Benefit,                             favouritism, or that may otherwise
                                                    affect you personally as an individual
or Favouritism
                                                 + Disclose any situation where you have
Guiding Principle: We will remove
                                                    a personal or familial relationship with
ourselves from any decision process                 an external party doing business with
or work duty that may result in an                  or interacting with the City that may
actual, potential or perceived personal             result in an actual, potential or perceived
gain or benefit. We remove ourselves                conflict of interest
from situations where there is an
actual, potential or perceived risk of           Frequently Asked Questions
favouritism. When we have access to
                                                 Q My sister just bid on a City contract in
confidential information relating to any             my work area. What should I do?
competition open to the public, we are
ineligible to compete.                           A You are obligated to disclose your
                                                     relationship to your supervisor at the
                                                     beginning of the process. If you are in a
What Does This Mean?
                                                     position to evaluate the bid, influence
Employees must remove themselves from                the selection of the successful bidder or
any decision process that may result in              manage the bidder’s performance, there
actual, potential or perceived personal              is an actual conflict of interest. Your
gain, favouritism, or benefit, and mitigate          supervisor must ensure you are not
potential and perceived conflicts of interest        involved in the decision-making process
by disclosing and mitigating conflict of             and do not have access to information
interest situations.                                 regarding the process that could be used
                                                     to influence decision makers.
Awarding of City tenders, employment
opportunities, land sales, and disposal of           If you are not involved in the decision-
surplus assets will be carried out impartially       making process, there may be a
– without any advantage or favouritism to            perceived or potential conflict of
themselves or others.                                interest that must be disclosed, and
                                                     you and your supervisor must agree to
Why is This Important?                               mitigation measures to ensure an actual
All City business must be conducted                  conflict does not arise.
fairly and impartially. Employees are
compensated for their services with tax          Q In my job, I drive a City pickup truck that
dollars. A City employee should not benefit          is being declared surplus. Can I buy it?
from their job beyond the compensation
                                                 A Yes. Once the City has properly declared
paid for the job.
                                                     the truck surplus and it is available for
                                                     sale to the public at large, you may
Things To Do                                         make an offer to buy it. You will not get
+ Remove yourself from any decision                  any greater consideration in the sale
     process that may result in actual,              process than any other person offering
     potential or perceived conflict by              to purchase the vehicle through an open
     resulting in personal gain, benefit or          sale process.

20
code of conduct

Q My brother-in-law is qualified for a job          include modifying the reporting
   I directly supervise. Can he be hired for        relationship and/or a change in position
   that position?                                   for one or both employees involved.

A No. According to the Hiring Procedure,
   immediate family members may not             Other Employment
   work in the same section, branch or
   department where direct supervision          Guiding Principle: We will only engage
   would create a conflict. Furthermore,        in other employment that does not
   no one may be hired, transferred             conflict with our City duties or the Code
   or promoted to a position in which           of Conduct or put us in competition
   a relative can be perceived to have          with services provided by the City.
   influence over their promotion
   or supervision.                              What Does This Mean?
                                                Other employment is permitted, but only
Q I work in Financial and Corporate             with organizations not in direct competition
   Services and my cousin has a consulting      with the City or that could potentially
   agreement with another department.           compromise City business, social, political
   What should I do?                            interests and objectives or its reputation
A Nothing. Since you were not involved          to the public.
   in the decision process that awarded
   the contract and do not have any             Why is This Important?
   involvement with that business, there        During paid working hours, your priority
   is no conflict. But, if you are concerned    must be to City service, above all other
   that a conflict may be perceived,            financial interests. City employees are
   you should disclose the situation in         expected to be loyal to the City. You cannot
   accordance with the City’s guidelines.       have other employment that undermines
                                                your ability to perform your City duties
Q I have started a romantic relationship        effectively or conflicts with those duties.
   with my supervisor. What should I do?

A The City discourages workplace                Things To Do
   relationships that can result in conflicts   + Refuse work from the City’s direct
   of interest, complaints of favouritism,         competitors.
   claims of sexual harassment and other
                                                + Get written approval from your
   employee morale problems. In this
                                                   Deputy City Manager or disability plan
   situation, you and your supervisor must
                                                   administrator before you accept outside
   promptly disclose this relationship to
                                                   employment during a leave of absence.
   the manager of your work area. The
   manager must take steps to address
   the supervisory-subordinate working
   relationship in order to remove actual
   or perceived favouritism along with
   any other potential conflicts. This may

                                                                                           21
code of conduct

Frequently Asked Questions                       personal capacity on behalf of an outside
                                                 organization must declare their involvement
Q I’m off work and receiving disability
                                                 to the Office of the City Clerk as well as to
     benefits. I can’t do the heavy, physical
                                                 their Deputy City Manager, and must do so
     labour my City job demands but I can
                                                 on their own time.
     run my home-based bookkeeping
     business. Is this a violation?
                                                 Why is This Important?
A Yes. Your disability management
                                                 If you are in a position to advise City Council,
     consultant must approve all outside
                                                 or its committees or boards, on a matter
     employment while you’re on
                                                 that you are personally involved in, your
     disability leave.
                                                 involvement could be seen as favouritism
                                                 or conflict of interest. It must be clear
Q I work as a mechanic for the City of           to everyone involved that your outside
     Edmonton and would like to get a            interests, volunteer work or other personal
     part-time job as a mechanic. Is this        activities are not related to your position as
     permissible?                                a City representative, and that the advice
A Yes. You can take the job as long as the       you give considers only the best interests
     service is not in direct competition with   of the City.
     the City and the service is not performed
     on City time or using City assets.          Things To Do
                                                 + Let people in your community group
                                                     know about the City’s Code of Conduct
Appearances Before Council
                                                     and in particular, that you must be
Guiding Principle: We will not, in our               careful to ensure you avoid any possible
capacity as a City employee, appear                  conflict of interest with your duties as a
before City Council, or its committees               City employee.
and boards, on matters affecting                 + Advise the Office of the City Clerk as
an external organization, where we                   well as your Deputy City Manager of
have any involvement that could be                   any appearance before Council that may
considered a conflict of interest.                   cause conflict between your job duties
                                                     and outside activities.
What Does This Mean?
Employees who appear before City                 Frequently Asked Questions
Council, or its committee or boards, in their    Q I belong to a non-profit organization.
official capacity must not provide advice            May I appear before City Council
or recommendations that benefits them                on its behalf?
personally, prioritizes their personal views
or interests, or intentionally affects an        A Yes. You have the right to appear, on
external party adversely for personal gain.          your own time, before City Council,
Any advice provided in an official capacity          its committees and boards on behalf
should be in the best interests of the               of public groups, such as community
City. Employees who appear before City               leagues, athletic organizations and
Council, or its committees or boards, in their       charitable organizations. You also

22
code of conduct

    have the right to appear as a taxpayer,      many people uncomfortable. In order to
    elector or owner on issues specified in      respect all beliefs, political activity is not
    the Municipal Government Act, but must       allowed in the workplace. Political views
    do so on your own time and not in a          and activities are important to many
    City uniform.                                employees, but the work environment and
                                                 time should be devoted to City business.
Q May I appear before City Council on
    behalf of my private company?                Things To Do
A Yes. However, you must appear on your          + Get written permission from your
    own time and declare your involvement            Deputy City Manager before you
    to the Office of the City Clerk as well as       engage in any political activity at your
    to your Deputy City Manager prior to             place of work.
    the appearance.
                                                 Frequently Asked Questions

Political Activity                               Q Can City employees run for
                                                     political office?
Guiding Principle: We must not
engage in any political activity or              A Yes. Procedures for this situation are
                                                     outlined in City Policies related to
electioneering during normal working
                                                     Leaves of Absence and the applicable
hours at our place of work without
                                                     election legislation.
the written permission of our Deputy
City Manager.                                    Q Can I campaign for a union position
                                                     at my work site?
What Does This Mean?
                                                 A All political activity and elections in the
Political activities, such as canvassing,
                                                     workplace, including union elections,
campaigning and fundraising, that aim to
                                                     require the approval of your Deputy
advance an individual’s or group’s political
                                                     City Manager.
interests will not be permitted in the
workplace during normal working hours.
                                                 Q Can I wear a badge with a political
All employees have the right to take part
                                                     statement while I perform my
in political activity and electioneering, but
                                                     City duties?
only on their own time and using personal
resources. City assets must not be used for      A No. Political propaganda is not
political activity at any time.                      permitted at your place of work.

Why is This Important?                           Q My spouse is running for political
The fact that we work for a municipal                office. Can I accept contributions to
government presents a unique situation; our          the campaign while I’m at work?
workplace is a highly political environment      A No. City employees are not permitted
where opinions vary widely and strongly              to raise or to contribute funds to
and can be a source of potential conflict.           political campaigns while at their
Furthermore, political discussions make              place of work.

                                                                                                23
code of conduct

Other Reference Documents
1.   Respectful Workplace Policy

2.   Social Media Guidelines

3.   Occupational Health and Safety Directive

4.   Cit-e File Classification and Retention Schedule

5.   Connected City Initiative

6.   City of Edmonton Leadership Competencies and Cultural Commitments

7.   Leave of Absence Without Pay Directive

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