Expectation of Ethical Conduct - Information Bulletin
To Licence Holders under the Cannabis Act and Applicants
The purpose of this information bulletin is to state Health Canada's expectation of ethical conduct on the part of licence holders and licence holder applicants under the Cannabis Regulations (CR).
The purposes of the Cannabis Act (CA) and its regulations are to protect public health and public safety. Protecting the integrity of the control of the production and distribution of cannabis under the CA is a priority for Health Canada.
The CR set out stringent requirements for safety and security in respect to the production and distribution of cannabis.
In the case of a licence for cultivation, processing, or sale, the CR require key personnel, including but not limited to directors, officers, and any individual who exercises, or is in a position to exercise, direct control over the corporation, cooperative, or partnership, to hold a security clearance granted under the regulations. The purpose of the security clearance process is to identify information that could be relevant in determining that the applicant does not pose an unacceptable risk to the integrity of the control of the production, distribution, and sale of cannabis.
Further to these requirements, individuals conducting business or wishing to conduct business involving cannabis are advised that they should at all times demonstrate a high standard of ethical conduct in carrying out their activities. Health Canada expects licence holders and licence holder applicants to be honest and ethical in how they conduct their business, and act professionally and in good faith in all interactions with clients, provinces and territories, and with Health Canada officials. They should also take care to avoid any situation that could compromise the health and safety of Canadians; for example, giving or offering inappropriate direct or indirect payments or inducements to any individual or organization.
Failure to Meet Expectations of Ethical Conduct
Accurate public information on the cannabis industry is fundamental to the integrity of the CR.
If a licence holder or licence holder applicant misrepresents the status of their application or their relationship with Health Canada officials, Health Canada may publicly correct any inappropriate or inaccurate statements and could pursue other regulatory compliance measures in line with its Compliance and Enforcement Policy for the Cannabis Act, if necessary. Moreover, inappropriate or inaccurate information provided in relation to an application will be considered in light of overarching public health and safety objectives of the regime and could affect licensing decisions.
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