Founded Disclosures of Wrongdoing

Requirement to Report

In accordance with section 11 (c) of the PSDPA, if wrongdoing is found as a result of a disclosure, the chief executive must

"promptly provide public access to information that

(i) describes the wrongdoing, including information that could identify the person found to have committed it if it is necessary to identify the person to adequately describe the wrongdoing; and

(ii) sets out the recommendations, if any, set out in any report made to the chief executive in relation to the wrongdoing and the corrective action, if any, taken by the chief executive in relation to the wrongdoing or the reasons why no corrective action was taken"

In accordance with section 16.5 of the Access to Information Act and section 22.3 of the Privacy Act, information created for the purpose of making a disclosure of wrongdoing or in the course of an investigation into a disclosure under the PSDPA is protected and cannot be released.

Internal Disclosure of Wrongdoing investigations are conducted by the Directorate of Special Examinations and Inquiries (DSEI) on behalf of the Senior Officer. DSEI reports do not contain specific recommendations pertaining to administrative or disciplinary sanctions to be taken against an individual when the allegations of wrongdoing have been founded. This is the purview of management/the chain of command.

In keeping with the requirements of the Act, the following information with respect to founded disclosures within the Department of National Defence is made public.

Founded Wrongdoings for Fiscal Year 2017/18:

(1) Gross Mismanagement

On 16 October 2017, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Public Servants Disclosure Protection Act (PSDPA). The discloser raised two allegations at a specific Canadian Armed Forces (CAF) base in Canada.

  1. that base authorities had entered into an agreement with a transportation company, to provide free ‘shuttle bus’ services on a regular schedule to take military and civilian personnel from the base to the local community and back; and
  2. that base authorities were making annual payments in the amount of $20K, to a local medical clinic with no documentation to support such payments.

The subsequent investigation conducted by the Directorate of Special Examinations and Inquiries (DSEI) concluded the following:

  1. that the agreement in place between the DND and the transportation company was not actually a valid contract.  This resulted in legal liability concerns which were never addressed.  In addition, the former Base Commander had neither the public nor non-public contracting authority to enter into a sole source non-competitive agreement with the transportation company; and that payment to the transportation company through a non-contractual agreement, constitutes a misuse of public funds and a breach of government contracting regulations; and
  2. that a site specific pilot project was approved at the national level to support a local civilian medical clinic from May 2009 to October 2011.  This pilot project was considered necessary in order to retain the clinic’s presence in the community, thereby ensuring that DND employees and CAF family members had reasonable access to civilian medical care.  The investigation was not able to identify any local or national level documentation to support the continued annual payments beyond the original May 2009 to October 2011 pilot project.  Despite the lack of any documentation, the Base Commander authorized the continued annual payments to the medical clinic using public funds; and that although the base authorities were unable to produce any documentation in support of the annual payments to the medical clinic beyond the pilot project, DSEI considers that the action taken by base authorities to ensure continued access to civilian medical services does not constitute serious wrongdoing under the PSDPA.    

The investigation report contained the following recommendations:

  • The current Base Commander immediately cancel the existing agreement with the transportation company.  A formal contract be put in place to obtain the transportation services required for DND and CAF members and their families.  This includes the involvement of financial and legal experts before the contract is signed.
  • The current Base Commander, along with representatives from Military Personnel Command, conduct a review of the current situation regarding the current civilian medical support available, and take appropriate steps to ensure appropriate medical services are available to civilians at this CAF base.

The DND Senior Officer has informed senior management of the findings of the DSEI investigation. No further action is required.

(2) Gross Mismanagement

On 16 October 2017, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Canadian Armed Forces Disclosure Process (CAF DP). The discloser raised an allegation that a senior CAF officer placed themselves in a Conflict of Interest (COI) situation.  Specifically, the senior officer intervened in the CAF recruiting process in an attempt to give their dependent an advantage, for which the dependent was not entitled.

The subsequent investigation conducted by the Directorate of Special Examinations and Inquiries (DSEI) concluded that the actions of the senior CAF officer did constitute a personal COI, contrary to the DND and CF Code of Values and Ethics.  An assessment of the seriousness of the wrongdoing, determined that the actions of the senior officer constitutes a serious breach of the DND and CF Code of Values and Ethics; specifically the expected behaviour of “Integrity” – para 3.2 which states, “Never using their official roles to inappropriately obtain an advantage for themselves or to advantage or disadvantage others.” 

The DND Senior Officer (ADM(Review Services)), has informed senior CAF management of the findings of the DSEI investigation.  The chain of command was advised of the findings, so that appropriate action could be taken.  No further action is required.

Founded Wrongdoings for Fiscal Year 2016/17:

(1) Gross Mismanagement, and a serious breach of the DND and CF Code of Values and Ethics
On November 24, 2016, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Public Servants Disclosure Protection Act (PSDPA).  The discloser raised an allegation that Human Resources (HR) hiring irregularities had occurred regarding the staffing of several new Public Service (PS) positions. Specifically, that a majority of the new PS positions had been given to serving or recently retired senior CAF officers working at the unit. Several of these officers were involved in the unit reorganization and the creation of the new PS positions.

The subsequent investigation conducted by the Directorate of Special Examinations and Inquiries (DSEI), and reviewed by Defence Ethics Programme, concluded the following:

  • Several senior CAF officers who were appointed into indeterminate positions, breached Defence Administrative Orders and Directives (DAOD) 7021-2 by failing to file a Confidential Report declaring their post-employment;
  • Several senior CAF officers breached DAOD 7021-1 by placing themselves in a personal conflict of interest (COI) when they participated in the initial reorganization of the unit and subsequently applied for these newly created PS positions. These individuals additionally placed the unit in an organizational COI;
  • Several senior CAF officers, and DND employees involved in the staffing processes breached DAOD 7021-1 by placing themselves in a personal COI when they participated in the Selection and Appointment Boards given existing subordinate/superior reporting relationships between members of the boards and the applicants;
  • Several senior CAF officers, and DND employees breached the DND/CAF Code of Values and Ethics due to their conduct during the staffing processes of the newly created positions, by failing to respect the dignity of all persons (Ethical Principal 1), and failing to serve Canada before self (Ethical Principal 2);
  • Several senior DND employees breached the PS Code of Values and Ethics due to their conduct during the staffing processes of the newly created positions by failing to show integrity (Ethical Behaviour 3); and
  • Several senior CAF officers and DND employees breached the PS Staffing Values of transparency, fairness, and access, by the manner in which the staffing processes were conducted.

The investigation report contained the following recommendations:

  • That the Level 1 Organization (L1) consider re-examining the appointments made under the competition processes investigated;
  • That the L1 ensure compliance with DAOD 7021-1, Conflict of Interest and DAOD 7021-2, Post-Employment, where applicable; and
  • That the L1 consider taking steps to restore workplace relations.

The DND Senior Officer has informed senior CAF management of the findings of the DSEI investigation and the Department has committed to undertaking the following corrective action:

  • Investigate the appointments and processes and recommend any corrective action deemed appropriate;
  • Move towards agile monitoring of the staffing regime across the Department;
  • Review the training course content for the “Staffing Sub-delegation Training for Managers” and enhance the sections on Values and Ethics and Conflict of Interest;
  • Include in the Second Career Assistance Network (SCAN) and Executive SCAN seminars reinforcement of DAOD 7021-1, Conflict of Interest;
  • Take steps to restore workplace relations based upon findings of subsequent investigations; and
  • Confirm that the current procedures in place ensures compliance with DAOD 7021-2, Post-Employment.

(2) Reprisal

  1. On 09 December 2016, the Internal Disclosure Office (IDO), Directorate of Special Examinations and Inquiries (DSEI) with Assistant Deputy Minister (Review Services), received a disclosure of wrongdoing from a CAF member, submitted under the Canadian Armed Forces Disclosure Process.  The discloser alleged that he suffered the following acts of reprisal for having previously submitted a harassment complaint against his immediate supervisor: threats of disciplinary measures; inappropriate remedial measures (initial counselling and a recorded warning); low assessment on annual performance evaluation report; and an unnecessary training deployment when a closer to home location was available.
  2. The subsequent investigation conducted by the DSEI concluded that certain members of the discloser’s Chain of Command (CoC) breached the DND and CAF Code of Values and Ethics by taking acts of reprisal against the discloser.  Specifically:
    • A Senior Officer committed an act of reprisal against the discloser when threatening disciplinary action and/or release from the CAF for making a ‘bad faith’ harassment complaint against the discloser’s immediate supervisor;
    • A Senior Officer publicly accused the discloser of making a ‘bad faith’ harassment complaint. When asked why he made this public statement, the Senior Officer stated that he believed a contentious statement within the Harassment Complaint to be false, and therefore concluded that the harassment complaint was made in bad faith.  The investigation concluded that the ‘contentious statement’ was in fact true;
    • The discloser had requested an accommodation from the CoC to carry out On Job Training (OJT) closer to his home unit.  The decision by a Senior Officer to deploy the discloser to another province, when the discloser could have conducted his OJT at a significantly closer unit) contravenes DAOD 5015-0 Workplace Accommodation – ‘family status’ grounds; and
    • Based on the direction of the Senior Officer, there was a concerted effort by the CoC to prevent the discloser from submitting complaints under authorized CAF recourse mechanisms (harassment complaint and a grievance).  The various statements made by five other members of the discloser’s CoC could be perceived to be threats of reprisal.
  3. The investigation has identified a concerted effort by the discloser’s CoC to arbitrarily dismiss the original harassment complaint, and prevent him from submitting another harassment complaint or a grievance.  Based on this information, the Internal Disclosure Office has determined that members of the discloser’s CoC committed multiple acts of reprisal against the discloser, contrary to the Canadian Armed Forces Disclosure Process, and Queens Regulations and Orders 19-15 Prohibition of Reprisals.
  4. The investigation report contained the following recommendations:
    • That the Base/Wing Commander ensure all acts of reprisal against the discloser cease immediately, and that appropriate corrective action be taken to mitigate any ongoing or long term impact suffered by the discloser as a result of the acts of reprisal taken by his CoC;
    • That the Base/Wing Commander address the actions of the Senior Officers and other members of the discloser’s CoC for their acts of reprisal and their concerted efforts to prevent the discloser from making a submission under authorized CAF recourse mechanisms; and
    • That the Base/Wing Commander take this opportunity to ensure all Base/Wing personnel are aware of the expected level of behaviour of DND employees and CAF members in accordance with the DND and CAF Code of Values and Ethics, specifically: paragraph 5.3, Table 2, Specific Values #1. Integrity; and paragraphs 6.1.4 and 6.2.3 which state that Supervisors, managers and CF Leaders “… at all levels, are expected to create a healthy ethical culture that is free from reprisal.”
  5. The DND Senior Officer has informed senior management of the findings of the DSEI investigation. No further action is required.

(3) Gross Mismanagement

On 15 March 2017, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Canadian Armed Forces Disclosure Process. The disclosure alleges that a number of Canadian Armed Forces (CAF) organizations failed to take appropriate action to ensure that numerous disciplinary and administrative measures have been properly actioned and documented.

The subsequent investigation conducted by the Directorate of Special Examinations and Inquiries (DSEI) concluded the following:

  • This issue had been previously identified in 2002;
  • The direction provided to implement the disciplinary and administrative measures was not standard;
  • Confirmation of the corrective action taken was not tracked at the national level; and
  • A significant number of disciplinary and administrative measures had not been addressed.

Based on the fact that this issue had been previously identified in 2002, and that the problem still existed in 2017, the Internal Disclosure Office has determined that the ongoing wrongdoing identified during the course of this investigation constitutes ‘gross mismanagement’ under the Canadian Armed Forces Disclosure Process.   

The investigation report contained the following recommendations:

  • At the end of each fiscal year, all commands submit an annual report confirming all disciplinary and administrative corrective measures taken within their organization for inclusion in a national level annual report.
  • A thorough review be conducted of all the discrepancies identified during the course of the investigation, to ensure that appropriate disciplinary and administrative corrective measures have been taken and properly documented;
  • The Canadian Forces Logistics Training Centre include the administration of administrative and disciplinary measures in its training for Logistics and Human Resources professionals; and
  • Action be taken to establish a national level oversight capability responsible for ensuring all future disciplinary and administrative measures are actioned and documented.  This includes the development of a comprehensive DAOD which outlines the procedures required by all parties to ensure all disciplinary and administrative measures have been taken, and that confirmation of the action taken has been provided to the national level monitoring authority;

The DND Senior Officer has informed senior management of the findings of the DSEI investigation. Action has been initiated across the CAF to correct the deficiencies identified in this investigation:

  • Promoting awareness of the monitoring function and to inform and remind Commanding Officers of their obligations in accordance with QR&O;
  • Issuing a new CANFORGEN in order to clarify the roles, responsibilities, and procedures surrounding the implementation monitoring framework, including the role of the monitoring authority;
  • A case management system is in the process of being rolled out to facilitate monitoring of the implementation of administrative and disciplinary measures;
  • Updating Standard Operating Procedures to ensure weekly monitoring of messages and responses, and regularly sending instructions and reminders to units and Commanding Officers, as well as a quarterly report to L1 Commanders and Chief of Staff Vice Chief of the Defence Staff (COS VCDS);
  • Establishing Standard Operating Procedures that would include the reissuance of a CANFORGEN every 3 years to ensure that it remains relevant in unit orderly rooms;
  • Through a verification analysis, confirming any outstanding administrative and disciplinary measures dating back to 2010 and informing COS VCDS and units accordingly;
  • Working with the Canadian Forces Logistics Training Centre to augment the training program on the administration of administrative and disciplinary measures implementation.

Founded Wrongdoings for Fiscal Year 2014/15:

(1) Misuse of Public Property, and a serious breach of the DND and CF Code of Values and Ethics.

On 8 October 2014, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Canadian Armed Forces Disclosure Process. The disclosure alleges that a Canadian Armed Forces (CAF) member had misused public property and that a CAF supervisor failed to take appropriate action to prevent the misuse of public property. Specifically, the following allegations were made:

  • Misuse of Public Property – It was alleged that a CAF member lived in military accommodations free of charge from December 2011 to May 2012 (182 days) and from October 2012 to May 2013 (242 days).
  • A serious breach of the DND and CF Code of Values and Ethics – It was alleged that a CAF supervisor knowingly allowed the CAF member in question to live free of charge in military accommodations for an extended period of time.

The subsequent investigation conducted by the DSEI concluded the following:

  • The allegation of Misuse of Public Property by the CAF member was founded.
  • The allegation of a serious breach of the DND and CF Code of Values and Ethics by the supervisor was founded.

The investigation report contained the following recommendations:

  • Recovery action be initiated against the CAF member and that the member be required to pay for the 424 days of free accommodations he/she received.
  • That the investigation report be forwarded to the supervisor’s chain of command for action as they deem appropriate.

The DND Senior Officer has informed management of the findings of the DSEI investigation. No further action is required.

(2) Conflict of Interest, and a serious breach of the DND and CF Code of Values and Ethics.

On 27 February 2015, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Public Servants Disclosure Protection Act. The disclosure alleges that a DND employee worked on a contract for another government department while on a period of sick leave and receiving sick leave benefits from DND. The investigation sought to determine the circumstances surrounding the alleged contract with the other government department, and determine whether or not the employee breached a policy or regulation.

The subsequent investigation conducted by the DSEI concluded:

  • that the DND employee was in violation of Defence Administrative Orders and Directives (DAOD) 7021-1, Conflict of Interest, for not having submitted a Confidential Report to declare outside employment. The investigation confirmed that the DND employee had been previously advised of the requirement to file a Confidential Report when working for another government department, and had previously submitted a Confidential Report for a prior and non-related employment.
  • that the DND employee was in an apparent conflict of interest by engaging in outside employment with another government department while in receipt of sick leave benefits from DND; and
  • that the violation of DAOD 7021-1, the apparent conflict of interest, along with the ethical expectations incumbent upon a DND manager, resulted in the determination that the DND employee’s actions constituted a serious breach of the DND and CF Code of Values and Ethics.

The investigation report contained the following recommendations:

  • The employee was counselled as to the obligations under the DND and CF Code of Values and Ethics and was required to submit Confidential Reports for all previous and current outside employment; and
  • The sick leave granted for the period of the overlap was reversed and attributed to other leave without pay, thus requiring the repayment of the sick leave benefits.

Founded Wrongdoings for Fiscal Year 2013/14:

(1) Contravention of an Act of Parliament or any regulation made under any such Act, and a serious breach of the DND and CF Code of Values and Ethics.

On 6 May 2013, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Public Servants Disclosure Protection Act (PSDPA). The disclosure alleges that Department of National Defence (DND) employees and Canadian Armed Forces (CAF) members had breached Government Contracts Regulations and government and departmental policies, and that a CAF member committed a serious breach of the DND and CF Code of Values and Ethics. Specifically, the following allegations were made:

  • Contravention of any Act of Parliament or of the legislature of a province, or of any regulation made under any such Act – It was alleged that individuals knowingly circumvented Treasury Board contracting policy, and departmental contracting regulations to obtain the services of a specific contractor.
  • A serious breach of the DND and CF Code of Values and Ethics – It was alleged that an individual used his/her position to hire a member of his/her family.

The subsequent investigation conducted by the DSEI concluded the following:

  • The allegation of a contravention of any Act of Parliament or of the legislature of a province, or of any regulation made under any such Act was unfounded.
  • The allegation of a serious breach of the DND and CF Code of Values and Ethics was founded.

The investigation report contained the following recommendations:

  • As the serious breach of the DND and CF Code of Values and Ethics was conducted by an individual who has since retired, no further action was taken regarding this finding of wrongdoing.

The DND Senior Officer has informed management of the findings of the DSEI investigation. No further action is required.

Founded Wrongdoings for Fiscal Year 2012/13:

(1) Gross Mismanagement, and a serious breach of the DND and CF Code of Values and Ethics.

On 30 Oct 12, the departmental Internal Disclosure Office (IDO) received a disclosure of wrongdoing pursuant to the Public Servants Disclosure Protection Act (PSDPA). The discloser alleges that a Department of National Defence (DND) employee committed an act of Gross Mismanagement, and a serious breach of the DND and CF Code of Values and Ethics. Specifically, the following allegations were made:

  • Gross Mismanagement – It was alleged that the individual in question:
    • Imposed undue influence on his/her staff to hire a member of his/her family;
    • Imposed undue influence on his/her staff to hire family friends; and
  • A serious breach of the Values and Ethics Code for the Public Sector – It was alleged that the individual in question:
    • Was away from his/her place of work for 40 working days without authority; and
    • Failed to submit a leave request for personal vacation time while on education leave.

The subsequent investigation, conducted by the Directorate of Special Examinations and Inquiries, concluded that:

  • Gross Mismanagement.
    • The allegation that the individual Imposed undue influence on his/her staff to hire a member of his/her family was founded;
    • The allegation that the individual imposed undue influence on his/her staff to hire family friends was unfounded.
  • A serious breach of the Values and Ethics Code for the Public Sector.
    • The allegation that the individual was away from his/her place of work for 40 working days without authority was founded; and
    • The allegation that the individual failed to submit a leave request for personal vacation time while on education leave was founded.

The investigation report contained the following recommendations:

  • That the DND regulation regarding educational leave is deficient and requires re-writing; and
  • That management initiates recovery action regarding the manager’s 40 days of unauthorized leave.

The DND Senior Officer has informed management of the findings of the DSEI investigation. Additional information will be posted when available.

Founded Wrongdoings for Fiscal Year 2011/12:

(1) Contravention of an Act of Parliament or any regulation made under any such Act, misuse of public funds, gross mismanagement, and knowingly directing or counselling a person to commit a wrongdoing.

On 13 February 2012, the DND IDO received a disclosure pertaining to alleged wrongdoings by a CF member and a DND employee. Specifically, the following allegations were made:

  • Contravention of any Act of Parliament or of the legislature of a province, or of any regulation made under any such Act – It was alleged that individuals knowingly submitted fraudulent documentation in order to circumvent Treasury Board contracting policy, departmental contracting regulations, and delegation of authority responsibilities.
  • A misuse of public funds – It was alleged that an individual used public funds to purchase items to be used as retirement gifts.
  • Gross mismanagement – It was alleged that individuals within the organization were aware of and condoned the falsification of documentation in order to make purchases with end-of-year funding.
  • Knowingly directing or counselling a person to commit a wrongdoing – It was alleged that an individual knowingly directed subordinates to submit fraudulent documentation in order to circumvent Treasury Board policy, departmental contracting regulations, and delegation of authority responsibilities.

The subsequent investigation conducted by the DSEI concluded the following:

  • The allegation of a contravention of any Act of Parliament or of the legislature of a province, or of any regulation made under any such act was founded.
  • The allegation of a misuse of public funds or a public asset was founded; however, management had already taken immediate action to return the items when the misuse of public funds became known.
  • The allegation of a gross mismanagement in the public sector was founded.
  • The allegation of knowingly directing or counselling a person to commit a wrongdoing was founded.

The investigation report contained the following recommendations:

  • All personnel within the organization involved in contracting and procurement activities should receive immediate refresher training on Treasury Board contracting policy, departmental contracting regulations, and their delegation of authority responsibilities.
  • Greater oversight should be placed on the organization’s procurement and contracting activities.
  • Management should include a process within the current compliance program to conduct formal reviews of unit procurement activities at bases and wings across the country.

The DND Senior Officer has informed management of the findings of the investigation. Upon being advised that an investigation was initiated, delegated authority for contracting and procurement for all personnel within the organization was rescinded and remained with senior management. Following the issuance of the DSEI report, all recommendations were implemented.

Founded Wrongdoings for Fiscal Year 2010/11

(1) Gross Mismanagement, Misuse of Government Funds and Knowingly Directing or Counselling a Person to Commit a Wrongdoing

On 8 March 2011, the DND IDO received a disclosure pertaining to the alleged wrongdoing by several DND employees, specifically:

  • Gross Mismanagement and Misuse of Government Funds – it was alleged that: there were a number of personnel who routinely proceeded on excessive Temporary Duty travel which was unauthorized and seen as unnecessary, and some employees were frequently absent from the workplace, without authority; and
  • Knowingly Directing or Counselling a Person to Commit a Wrongdoing – It was alleged that one individual instructed his/her staff to always book full-fare economy airfares.

The subsequent investigation, conducted by the Directorate of Special Examinations and Inquiries, concluded that:

  • the allegation of gross mismanagement and misuse of Government funds was unfounded; however;
    • one individual was found to have travelled extensively but with authorization by his/her direct supervisor,
    • one individual was reimbursed for some travel to which he/she was not entitled, and
    • this same individual was absent from the workplace without authority for a significant period of time; and
  • the allegation that the individual directed subordinate staff to always book full-fare economy airfares was founded.

The investigation report contained the following recommendations:

  • when requesting travel authorization, the individual should provide an agenda or detailed breakdown of travel dates requested so that the supervisor would know exactly what he/she was authorizing;
  • the individual’s travel and hours of work be closely monitored;
  • the organization seek legal and HR advice with respect to financial recovery to cover the costs associated with extra travel days authorized but not entitled to and for the days he/she was absent from the place of work without authority.

Management has been informed of the findings and recommendations of the DSEI investigation. The management corrective action plan has fully addressed all of the DSEI recommendations and has put a process into place which will increase oversight and governance. Management has also confirmed that financial recovery has been actioned.

Founded Wrongdoings for Fiscal Year 2009/10

(1) Contravention of an Act of Parliament and Misuse of Public Funds

On 20 November 2009, the DND Internal Disclosure Office (IDO) received a disclosure pertaining to the alleged contravention of contracting regulations and misuse of public funds. Specifically:

  • Contravention of Contracting Regulations. It was alleged that the manager improperly hired a consultant on a series of Call-Ups against Temporary Help Services Standing Offer Arrangements over a two year period; and
  • Misuse of Public Finds. It was alleged that the manager paid the consultant in excess of $500,000 over a period of just less than two years, more than five times the annual rate of pay for the vacant position.

The subsequent investigation, conducted by the Directorate of Special Examinations and Inquiries, concluded that the allegations were founded; the investigation report contained recommendations that:

  • The DND manager and staff should receive refresher training with respect to-
    • Obligations under the Financial Administration Act (FAA),
    • Contracting within DND,
    • Conflict of Interest, and
    • Employer-employee relationships; and
  • that the chief executive consider imposing administrative or disciplinary sanctions as deemed appropriate under the circumstances.

The DND IDO has informed management of the findings of the investigation and confirmed that corrective action has been taken. The DND manager has been counselled, and the manager and senior staff have undergone refresher training with respect to obligations under the FAA, contracting for services, conflict of interest and employer-employee relationships.

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