Annual Report on Employee Misconduct and Wrongdoing at Canadian Heritage 2024-25

On this page

• Message from Deputy Ministers
• Introduction
• Canadian Heritage context
  • Cases of financial mismanagement
  • Cases of harassment and violence
  • Cases of breaches of the Values and Ethics Code
  • Cases of administrative misconduct
  • Breaches of personnel safety
  • Violations of the Policy on Service and Digital
• External investigations
• Conclusion
• Appendix A: Definitions

Message from Deputy Ministers

This first edition of the Annual Report on Employee Misconduct and Wrongdoing at Canadian Heritage, is an important milestone in our collective journey towards a respectful, inclusive and accountable workplace.

This report reflects our deep desire to build a healthy, safe and caring environment where everyone can reach their full potential. It is a continuation of our cultural statement, which affirms our commitment to making inclusion, diversity, equity and accessibility pillars of our organizational culture.

We have approached this first report and the overall process with clear-eyed awareness, fully recognizing that no organization—no matter how well-intentioned—is entirely immune to inappropriate behavior. While the complete eradication of such situations remains an ideal that is difficult to achieve, it nonetheless guides our commitment to building an environment rooted in respect, dignity, and zero tolerance toward inappropriate behavior.

We aspire for every employee to feel fully confident in reporting any form of misconduct, without fear of retaliation, and with the assurance that their concerns will be met with seriousness, empathy, and rigor. We are also aware that not all situations involving inappropriate behavior are reported. As such, this report can only offer a partial reflection of reality. That is why we hope it will serve as a catalyst and a lever to foster honest conversations, raise awareness, and inspire concrete actions. We want this report to spark a collective, deep, and lasting reflection so that together, we can continue to advance our organizational culture toward an ever healthier, safer, and more inclusive workplace.

To all those who contribute to this effort every day, we thank you. Your commitment is the cornerstone of what we are building together.

Isabelle Mondou (she)
Deputy Minister

Andrew Brown (he | him)
Associate Deputy Minister

Introduction

This annual report is intended to increase transparency about the handling of misconduct and wrongdoing cases at Canadian Heritage. It provides a summary of misconduct and wrongdoing reported within the Department during the 2024-25 fiscal year, as well as investigations conducted by external agencies during that period. It also provides information on informal and formal mechanisms for employees to report issues.

Canadian Heritage context

Canadian Heritage extends its presence across 21 offices spread over six regions, weaving a cultural thread that spans the Nation from coast to coast to coast.

At the heart of the Department’s mission is an unwavering commitment to a healthy, safe, inclusive and respectful workplace. Every employee and manager, regardless of their role or location, actively contributes to bringing these values to life on a daily basis.

Canadian Heritage’s Values and Ethics Code outlines exemplary behaviour based on integrity, accountability, transparency and respect for others. It is not only a reference framework, but a real guide to foster a climate of trust and collaboration. The Code also encourages the reporting of inappropriate behaviour or wrongdoing, while ensuring confidentiality, protection from retaliation and fair treatment of each reported situation.

Wherever an employee is located they have a moral and professional responsibility to report any form of misconduct, regardless of the status or hierarchical level of the person involved.

Each complaint must be treated seriously, fairly, rigorously and diligently. No one should be afraid to do the right thing. Canadian Heritage is committed to protecting everyone’s privacy and everyone can count on their privacy to be respected and protected.

Cases of financial mismanagement

Reporting to the Chief Financial Officer Branch, the Accounting and Policy Operations Directorate is responsible, for the implementation of financial controls within Canadian Heritage.

Cases of financial mismanagement result in a loss of public funds or state assets. This may include, but is not limited to, suspected fraud; misuse, misappropriation or theft of government funds or assets; contracting or procurement fraud; misconduct by contractors; and mismanagement or misappropriation of funds.

In some cases of financial mismanagement, the investigation of the possible wrongdoing is conducted under the misuse of public funds or assets provision of the Public Servants Disclosure Protection Act. When it is established that the wrongdoing is justified, it must be made public.

During the period covered by this report, there were no cases of financial mismanagement resulting in a loss of public funds or assets.

Cases of harassment and violence

Reporting to the Office of the Ombuds, Wellness and Ethics, the Harassment and Violence Prevention and Resolution team is responsible for receiving and managing notices of harassment and violence incidents.

The department aims to ensure that the values of inclusion, equity and diversity are respected in the workplace and recognizes that these values are essential to ensuring a workplace free from harassment and violence.

In accordance with the Canada Labour Code, harassment and violence include any action, conduct, or comment — including of a sexual nature, that can reasonably be expected to cause offence, humiliation, or physical or psychological injury or illness to an employee. Serious cases may be considered acts of wrongdoing under the Public Servants Disclosure Protection Act when they constitute a significant breach of a code of conduct. In addition, if the wrongdoing is substantiated, it must be made public.

Over the 2024-25 fiscal year, the Office of the Ombuds, Wellness and Ethics team consulted with several employees and managers to listen to their concerns about their workplace. The following is a summary of the notices of occurrence received during the 2024-25 fiscal year:

• Number of consultations to discuss whether a specific contravention situation or the allegation process: 15
• Number of notices of occurrence received (including those transferred from previous years): 6
• Number of notices of occurrence completed in 2024-25: 4
• Number of notices of occurrence completed or resolved through the Informal Conflict Management System: 2
• Number of completed notices of occurrence that led to formal investigations (with recommendations issued by the investigator): 2

Cases of breaches of the Values and Ethics Code

Reporting to the Office of the Ombuds, Wellness, and Ethics, the Values and Ethics and Wrongdoing team is responsible for receiving and processing disclosure submissions under the Canadian Heritage Code of Values and Ethics, as well as those submitted under the Public Servants Disclosure Protection Act.

The Canadian Heritage Code of Values and Ethics outlines a broad range of behaviors that employees are expected to uphold and promote, in accordance with the core values of the public service and the expected behaviors that support them: respect for people, respect for democracy, integrity, sound stewardship of resources, and excellence.

A violation occurs when an employee fails to meet the expected values and ethics outlined in the Canadian Heritage Code of Values and Ethics. This may include, for example, the improper use of influence or abuse of access to resources, making false declarations or providing false personal information, issuing threats or intimidating a colleague, or failing to disclose a conflict of interest.

Some alleged breaches are investigated as potential wrongdoing under the Public Servants Disclosure Protection Act, when they constitute a serious breach of a code of conduct. If the wrongdoing is substantiated, it must be made public. When a disclosure is received, an admissibility analysis is conducted based on several criteria to determine whether an investigation should be initiated. Investigations are carried out as quickly and informally as possible, while maintaining the necessary rigor throughout the process.

During the 2024–25 fiscal year, the team from the Office of the Ombuds, Wellness and Ethics consulted with several employees and managers to hear their concerns about the workplace. Below is a summary of the incident notifications received during the 2024–25 fiscal year:

• Number of consultations to discuss a possible contravention or the allegation process: 4
• Number of disclosures received: 1

Cases of administrative misconduct

Reporting to the Human Resources and Workplace Management Branch, the Labour Relations’ team supports management in addressing cases of misconduct.

Cases of administrative wrongdoing and misconduct encompass a range of behaviours in the workplace, such as tardiness, absenteeism, unauthorized leave or personal activities during work hours, insubordination, failure to perform specific duties or functions or follow instructions, or misuse of government assets.

Management plays a crucial role in maintaining a healthy workplace.

While all complaints and allegations are received and assessed to ensure they are dealt with appropriately, not all allegations are subject to a formal investigation process. For cases of misconduct, where the information initially disclosed is insufficient to allow a decision to be made, an investigation process is initiated and may take the form of a fact-finding exercise or an investigation.

A fact-finding exercise is used when the situation is straightforward, the facts are undisputed, and minimal investigation is needed. When the situation is more complex and additional information is required, a formal investigation may be opened.

In some cases, the complaint or allegation may not be substantiated, rendering informal mechanisms more suitable. The Office of the Ombuds, Wellness and Ethics offers a variety of independent and confidential services, including the Employee Assistance Program and the Informal Conflict Management System, to support employees and to help restore a healthy work environment. In addition, the Labour Relations team under the Human Resources and Workplace Management Branch can assist managers in promoting and reinforcing the importance of the Canadian Heritage Values and Ethics Code and in addressing inappropriate behaviour.

During the reporting period, three cases of administrative misconduct or misconduct were found to be justified:

1. Absenteeism, unauthorized leave:
   • Incidents by a single employee: 2
     • Fact-finding exercise opened
     • Discipline imposed: a verbal reprimand in each case
     • Administrative actions taken: several letters of expectation
2. Insubordination, failure to perform duty or specific duties, or failure to follow instructions:
   • Employee-related incident: 1
     • Fact-finding exercise opened
     • Disciplinary action imposed: two written reprimands
     • Administrative action taken: a letter of expectation
3. Fraudulent behaviour by personal use of Canadian Heritage credit card:
   • Employee-related incident: 1
     • Fact-finding exercise opened
     • Discipline Imposed: suspension without pay
     • Administrative action taken revocation of card and coaching on values and ethics

Breaches of personnel safety

Reporting to the Chief Information Officer Branch, the Corporate Security Directorate is responsible for investigations related to personnel security. These investigations focus on the following areas:

• Information Security: Ensuring that classified information is handled properly and not shared without authorization.
• National Security: Assessing whether an employee’s behavior may raise concerns about their loyalty to Canada.
• Misconduct: Investigating internal threats such as unauthorized information sharing or espionage.
• Reliability Status: Reviewing the trust placed in an employee when issues arise that do not fall under other investigation categories.

If concerns arise regarding an employee’s behavior or on the background information they have provided, a review of their security status may be considered to ensure their loyalty and reliability. Over the course of fiscal year 2024-25:

• No security clearances were revoked or denied.
• One security clearance was reviewed and granted, with specific conditions attached.
• One security clearance review was initiated for an employee.
• 30 internal incidents were managed by the Branch, but none resulted in a breach.

Violations of the Policy on Service and Digital

Digital compliance and incident management

The Chief Information Officer Branch is responsible for enforcing the Policy and Directive on Service and Digital from the Treasury Board Secretariat. Violations include the inappropriate use of departmental networks and devices (Wi-Fi, phones, etc.) for criminal, disruptive activities or for handling sensitive data on unauthorized systems.

The cases are generally identified during internal investigations or by the Labour Relations Team. This year, ten cases of non-compliance with the National Joint Council Travel Directive were reported, involving the use of equipment abroad.

Mobile data monitoring

In 2024-2025, 16 alerts were received for data costs exceeding $500. It was found that 13 were related to official travel abroad, while the remaining three were due to misuse of employee's corporate mobile devices. Awareness and reimbursement measures have been implemented.

External investigations

Other Canadian entities can also conduct their own investigations about our department or staff, as part of their respective mandates. These investigations may involve interactions with police services, the Office of the Public Sector Integrity Commissioner, the Canadian Human Rights Commission, Employment and Social Development Canada, or the Public Service Commission.

No external investigations were undertaken by other Canadian entities in the 2024-25 fiscal year.

Conclusion

This first Report on Employee Misconduct and Wrongdoing at Canadian Heritage represents a step forward in increasing the department's efforts to ensure ethical conduct, accountability, and transparency. While challenges persist, our commitment remains clear: To maintain a culture of zero tolerance toward inappropriate behavior, where every voice counts, and every situation is handled with integrity.

Thank you to each one of you, at Central Administration and in the regional offices, for bringing to life every day the values based on integrity, responsibility, transparency, and respect for others that defines the Public Service.

Appendix A: Definitions

Administrative investigation

Gathering and analyzing information related to an incident of alleged misconduct to address any risk of harm and prevent future incidents.

Conflict of interest

A situation in which a public servant has private interests that could improperly affect the performance of his or her official duties and responsibilities, or in which a public servant uses his or her public office for personal gain.

A conflict of interest can be:

• real (exists in the present moment);
• apparent (perceived as such by a reasonable observer whether or not this is the case);
• potential (could reasonably occur in the future).

Disciplinary Process

A structured process for dealing with employees who have contravened departmental processes or policies. It consists of a series of steps.

Discrimination

Any action or decision that results in unfair or negative treatment of a person on the basis of prohibited grounds of discrimination such as race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, disability, and conviction for an offence for which a pardon has been granted (pardon or record suspension.

Fact-finding exercise

Limited scope assessment to identify the problem and clarify relevant facts. It is a matter of gathering information before deciding whether to proceed with a large-scale investigation.

Grievance

A written complaint that may be filed by a person on his or her own behalf, by a representative of a bargaining agent on behalf of a group of persons or, in the case of a policy grievance, by a bargaining agent or an employer.

Misconduct

Any action by which a person deliberately contravenes, among other things, a statute, regulation, rule, policy instrument of the department or the Treasury Board, an approved procedure, a departmental code of conduct or the Values and Ethics Code for the Public Sector. In short, an act by which an employee contravenes one of the obligations he or she accepted by becoming a public servant. For example, it can be a question of leave taken without authorization, insubordination, or a lack of punctuality.

Notice of occurrence

Is a formal mechanism under the Workplace Harassment and Violence Prevention Regulations used in workplace harassment and violence cases. It allows individuals to report incidents that they believe may involve harassment or violence. The notice includes details such as the date of the occurrence, the names of the principal and responding parties, and a description of the incident. Employers or designated recipients are required to respond to the notice within a specified timeframe and may initiate a resolution process to address the allegations.

Preliminary assessment

A limited scope assessment designed to help identify potential issues and scope of work to determine if further investigation is required.

Wrongdoing

The Public Servants Disclosure Protection Act defines wrongdoing as one or more of the following:

1. a contravention of an Act of Parliament or a regulation made under an Act of Parliament or a province, other than a contravention of section 19 of this Act;
2. misuse of public funds or property (PDF format);
3. gross mismanagement in the public sector (PDF format);
4. the act of causing – by action or omission – a substantial and specific danger to the life, health or safety of persons or to the environment, other than a danger that is inherent in the performance of a public servant’s duties and functions;
5. a serious breach of a code of conduct (PDF format) established under sections 5 or 6 of this Act;
6. knowingly directing or counselling a person to commit any of the wrongdoings referred to in clauses (a) to (e).

© His Majesty the King in Right of Canada, as represented by the Minister of Canadian Heritage, 2025
Catalogue No. CH1-53E-PDF
ISSN 2819-4411