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Treasury Board of Canada Secretariat Code of Conduct

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1. Introduction and application

In this section

1.1 Introduction

The Treasury Board of Canada Secretariat (TBS) supports the Treasury Board committee of ministers and acts as the administrative arm of the Treasury Board. Under the leadership of the President, we provide guidance and direction to help departments effectively implement government policies and priorities. This includes spending oversight, administrative leadership, regulatory oversight and people management. TBS’s responsibilities are at the core of a well-functioning and effective government. To carry them out, we are often entrusted with sensitive information and must work closely with each other and with colleagues from other federal institutions, ministers and exempt staff, citizens, stakeholder organizations, and many others.

As central agency employees, we occupy a privileged position in the administration of federal government business. This privilege comes with a responsibility to lead by example and to model the high standards expected of all federal public servants that are described in this Treasury Board of Canada Secretariat Code of Conduct (TBS Code of Conduct) and set out in the Values and Ethics Code for the Public Sector, Open and Accountable Government, the Conflict of Interest Act and the Lobbying Act.

This code of conduct is specifically designed to help all TBS employees understand and live up to these responsibilities in our daily work as public servants and to conduct ourselves in a manner that can bear the closest public scrutiny.

Managers, from team leaders to senior executives, occupy a position of influence and authority. They shape a positive workplace culture by setting an example of ethical behaviour and TBS values.

Regardless of your position, you should familiarize yourself with this document and the supporting resources. We encourage you to carefully review it and reflect on how it applies in your own situation.

1.2 Objective

The Public Servants Disclosure Protection Act requires all federal institutions to develop their own code of conduct to complement the Values and Ethics Code for the Public Sector.

The TBS Code of Conduct belongs to all of us and is designed to help us clearly identify what is meant by ethical behaviour in our workplace. It offers guidance on what is expected of us, in our day-to-day work and in our conduct both within and outside TBS.

The Values and Ethics Code for the Public Sector and the TBS Code of Conduct offer definitions of the public sector values and describe the behaviours required to uphold each value.

Every situation is unique and, as such, we must all use common sense and good judgment, guided by the principles of the TBS Code of Conduct. If you’re ever uncertain about how to proceed, you should seek advice from your immediate supervisor or the Values and Ethics Office by email at valuesandethics-valeursetethique@tbs-sct.gc.ca.

1.3 Application

This code applies to the following TBS employees:

  • indeterminate and term employees
  • individuals on leave without pay
  • students participating in student employment programs
  • casual, seasonal and part-time workers
  • individuals on secondment from other government organizations
  • individuals participating in exchange programs such as Interchange Canada

Employees who are members of a regulated profession should also adhere to the standards of any professional code of conduct that applies to them.

All TBS employees will be held accountable. A breach or violation of the values or expected behaviours stated in the Values and Ethics Code for the Public Sector and the TBS Code of Conduct may result in administrative or disciplinary measures, up to and including termination of employment.

2. Values and expected behaviours

In this section

The Values and Ethics Code for the Public Sector describes the following values:

  • respect for democracy
  • respect for people
  • integrity
  • stewardship
  • excellence

These values serve as a guiding framework for public servants in all their activities. They should not be viewed in isolation, as they are often interdependent and mutually reinforcing.

By embodying the values of the public sector, we contribute to preserving public trust in public institutions and help foster safe, inclusive and engaging work environments.

2.1 Respect for democracy

The system of Canadian parliamentary democracy and its institutions are fundamental to serving the public interest. Public servants recognize that elected officials are accountable to Parliament, and ultimately to the Canadian people, and that a non-partisan public sector is essential to our democratic system.

At TBS, we respect democracy by:

Providing impartial and accurate advice

  • Providing fair, equitable, non-partisan and impartial advice to decision makers in our own department and other departments and agencies
  • Providing complete, accurate information, well-thought-out analysis and advice to inform TBS decisions and to support the Treasury Board Ministers in their accountability to Parliament and Canadians

Maintaining professional conduct and loyalty

  • Ensuring that our public statements and actions do not interfere with our duty of loyalty and reflect positively on TBS and the Government of Canada
  • Exercising our individual rights to freedom of expression in a manner that does not negatively impact the credibility of, and public trust in, TBS and the Government of Canada
  • Loyally implementing the lawful decisions of our superiors and of ministers
  • Refraining from commenting publicly on behalf of TBS or the government without prior authorization from the departmental Head of Communications (media requests should be referred to the TBS Media Relations team at media@tbs-sct.gc.ca)

Respecting legal and ethical standards

  • Respecting the rule of law and carrying out our duties in accordance with legislation in a non-partisan and impartial manner
  • Respecting the confidentiality, privacy and security of information entrusted in us by our own organization and by other institutions, as well as by members of the Canadian public

See also: Social media

2.2 Respect for people

Treating all people with respect, dignity and fairness is fundamental to our relationship with the Canadian public and contributes to a safe and healthy work environment that promotes engagement, openness and transparency. The diversity of our people and the ideas they generate are the source of our innovation.

At TBS, we show respect by:

Respect and fair treatment

  • treating every person the way they would like to be treated—with respect, fairness, inclusion, consideration and compassion for their feelings and well-being
  • acting with civility and respecting, understanding, accepting and valuing everyone’s backgrounds, skills, perspectives and experiences
  • engaging with colleagues, clients, stakeholders and the Canadian public with openness, tact and respect

Mindfulness and equity

  • adjusting our behaviour to demonstrate mindfulness, fairness and equity in all our relationships, interactions and transactions, including in our relationships with colleagues from other institutions, stakeholders and the Canadian public by:
    • recognizing, accepting and valuing everyone’s unique attributes, including race, ethnicity, culture, gender identity or expression, sexual orientation, marital status, family status, religion, disabilities and other characteristics
  • collaborating by listening actively to one another, showing empathy and providing constructive feedback

Accessibility and safety

  • proactively addressing barriers to accessibility, both in our workplace and in the development of policies and services for the Canadian population
  • taking action to create and maintain a safe and healthy workplace that is free from harassment, discrimination and violence:
    • TBS supervisors promptly and effectively address any instance of harassment, discrimination or violence, regardless of whether a formal complaint has been made or the individual affected has come forward
    • TBS employees who experience or witness harassment or violence are encouraged to inform their manager or TBS’s Designated Recipient Unit, verbally or in writing, as soon as possible 

Professional development and inclusion

  • prioritizing ongoing professional development and awareness training to support reconciliation, equity, diversity, inclusion, accessibility, anti-racism and anti-oppression in all aspects of our work

2.3 Integrity

Integrity is the cornerstone of good governance and democracy. By upholding the highest ethical standards, public servants conserve and enhance public confidence in the honesty, fairness and impartiality of the federal public sector.

At TBS, we show integrity by:

  • acting at all times with integrity and in a manner that will bear the closest public scrutiny (strictly acting within the law is not always sufficient)
  • never using our official roles to inappropriately obtain an advantage for ourselves or to advantage or disadvantage others
  • taking all possible steps to prevent and resolve any real, apparent or potential conflicts of interest between our official responsibilities and our private affairs in favour of the public interest
  • acting in a way that maintains our employer’s trust by ensuring that our private activities don’t prevent us from doing our job, prevent TBS from operating efficiently, or jeopardize the integrity, objectivity or impartiality of the TBS or public service:
    • If you are charged with a serious offence or other serious violation under any federal, provincial or territorial law, statute or regulation, you must notify your supervisor without delay
    • We are mindful of what we post in our personal social media channels so that it doesn’t impact our effectiveness as an employee or undermine the impartiality of the federal public service

See also:

2.4 Stewardship

Federal public servants are entrusted to use and care for public resources responsibly, for both the short term and long term.

At TBS, we demonstrate stewardship by:

Financial management and accountability

  • effectively and efficiently using the public money, property and resources that we manage, in accordance with delegated authorities and the rules set out in the Financial Administration Act, and in any other related departmental financial policies, and keeping records that document and support financial decisions:
    • We use government property, such as documents, equipment and supplies for official purposes only, unless limited personal use has been authorized, and never for outside business interests or personal gain
    • When we leave our position, are transferred, reassigned, go on a long-term absence (for example, maternity leave), or when requested by an authorized person, we must return the property; any loss, theft or damage to property must be immediately reported to our supervisor
  • maintaining complete and accurate records and storing and organizing information properly in official TBS information repositories according to TBS and the Government of Canada’s guidelines on information and data management (for more information, refer to the Policy on Service and Digital and the Directive on Service and Digital)

Digital and network usage

Environmental and sustainable practices

See also: Protecting government information and systems

2.5 Excellence

Excellence in the design and delivery of public sector policies, programs and services is beneficial to every aspect of Canadian public life. Engagement, collaboration, effective teamwork and professional development are all essential to a high-performing organization.

At TBS, we demonstrate professional excellence by:

Quality and inclusivity in services

  • providing fair, timely, efficient and effective services that respect Canada’s official languages, and respecting the language rights of our public service colleagues and clients, in accordance with the Official Languages Act
  • continuously improving the quality of policies, programs and services that we provide by taking action to address gaps and accepting calculated risks
  • seeking out and incorporating diverse viewpoints in our work, including women, Indigenous Peoples, Black and racialized people, newcomers, faith-based communities, persons with disabilities, and 2SLGBTQIA+Footnote 1 people, in both official languages, to create and manage programs, services and policies that are inclusive and free from bias

Work environment and collaboration

3. Avenues for resolution

In this section

The Government of Canada is committed to promoting ethical practices in the public sector and providing a safe and positive environment for reporting unethical behaviour or disclosing wrongdoing.

3.1 Ethical issues

The expected behaviours outlined in the previous section are not intended to address every possible ethical issue that may arise. Instead, they provide guidance on how individual behaviours contribute to TBS’s organizational culture and credibility. Our actions matter.

If ethical concerns arise, you are encouraged to address and resolve them with your immediate supervisor. You can also seek advice and support from TBS’s Senior Disclosure Officer, TBS’s Values and Ethics Office or other subject matter experts.

3.2 Conflict, violence and harassment in the workplace

Employees at all levels are expected to resolve issues and conflicts in the workplace in a fair and respectful manner. You can do your part to maintain a healthy workplace by addressing and resolving conflicts as soon as they occur and by reporting all instances of violence or harassment.

3.3 Disclosure of wrongdoing

The Public Servants Disclosure Protection Act gives federal public service employees and Crown corporations a secure and confidential process for disclosing serious wrongdoing as set out in section 8 of the act, and provides protection from acts of reprisal.

If you have information about a serious breach of the Values and Ethics Code for the Public Sector, TBS Code of Conduct, or other suspected wrongdoing, you may seek advice or make a disclosure under the Public Servants Disclosure Protection Act in good faith to one of the following:

For more information on the Public Servants Disclosure Protection Act and TBS’s internal disclosure mechanism, refer to the Disclosure wrongdoing page on the TBS InfoSite.

3.3.1 Protection from reprisal

The Public Servants Disclosure Protection Act provides employees with protection against reprisals if they disclose wrongdoing. The disclosure process is confidential to protect the identity of employees in accordance with the act. Reprisals include any disciplinary measures such as demotion, termination of employment, and any other action or threat of action that hurts your employment or working conditions.

The Public Servants Disclosure Protection Act gives the Office of the Public Sector Integrity Commissioner the responsibility to investigate reprisal complaints.

4. Protecting government information and systems

In this section

4.1 Electronic networks

You are expected to be familiar with the Policy on Service and Digital, the Directive on Service and Digital, and the Guideline on Acceptable Network and Device Use when using Government of Canada electronic networks and devices, web tools, and services. Computer systems, software, equipment, networks, the Internet, Government of Canada intranet sites and email are for work-related activities or for approved, limited personal use only.

Personal use of electronic networks is acceptable if:

  • it is on personal time (breaks, lunch time, and the time before and after work)
  • it is not for financial gain for yourself or for someone else
  • it does not add to costs for TBS
  • it does not interfere with the conduct of government activities and operations

You should be aware that all information obtained, stored, sent or received using TBS’s electronic networks is subject to routine monitoring. Records are created and stored for every email (received, sent, filed or deleted) using TBS’s email system and for every web page visited and every download initiated. Records are also created and stored for every access made to client information.

When using government computer systems, equipment and software, including handheld devices, you must make every effort to protect the network from electronic security threats. You must guard against accidental or deliberate destruction of data and equipment, disclosure of sensitive information, theft and corruption, and exposure to viruses.

You are not authorized to travel outside Canada with TBS-issued devices and assets (for example, smartphones, tablets, notebooks) or to access TBS information when abroad. If there is an operational requirement to travel outside Canada with TBS devices as assets, you must obtain the necessary departmental authorization and the approval of TBS’s Security Services. A detailed list of cyber security best practices while travelling is available on the Cyber security while travelling web page.

Appendices A and B of the Directive on Service and Digital outline examples of acceptable and unacceptable personal use and of unlawful network activities that you should be aware of.

4.2 Artificial intelligence

When using artificial intelligence (AI), you should adhere to TBS’s guiding principles, the public service guidelines on using generative AI in your daily work, the Guideline on Acceptable Network and Device Use, and all other guidance developed for federal public servants.

If you are using AI in your work, you must validate the information generated, and you should ensure that your outputs are inclusive, unbiased and accurate.

Never input protected, classified or personal information into public generative AI tools. AI should be used only with unclassified information. You must also comply with the Privacy Act, the Policy on Service and Digital and the Directive on Service and Digital.

4.3 Intellectual property

Under the Copyright Act and the Public Servants Inventions Act, anything you create, design, develop or produce while performing your duties as part of your employment with the Government of Canada (for example software, work methods, manuals, policies, procedures, briefing notes, forms, evaluation systems and DVDs) becomes the exclusive property of the government. As a result, you are not allowed to sell, market or otherwise profit from these creations, either during your employment with TBS or after leaving the Government of Canada, even if you worked on or made improvements to these items outside of working hours.

In addition, using graphics, photos or references created by an external copyright holder requires their permission before using the materials. Using copyrighted material without permission exposes TBS to the risk of having to pay reparations and damages to the copyright holder.

4.4 Preserving confidentiality and the secure handling of information

You are responsible for protecting personal information, including that of TBS employees and the public. When you become a public servant, you take an oath or make a solemn affirmation that you will not disclose information on any matter obtained through your employment unless legally authorized.

Official information should only be used for government purposes, not for personal gain. You must not access or share information for personal reasons without a legitimate need.

Be cautious about discussing sensitive information in public places (for example, taxis, restaurants, airports), as others may overhear. Only share information with other government employees, including TBS employees, on a need-to-know basis.

The Privacy Act and the Foreign Interference and Security of Information Act regulate the handling of personal information. In a hybrid work environment, follow these guidelines to ensure information security:

  • Use secure locations and equipment for handling and sharing information
  • Follow proper procedures for securely transporting and storing information
  • Dispose of information securely
  • Follow the Guide on the Use of Generative Artificial Intelligence
  • Apply the need-to-know principle when sharing information

Classified information is accessible only to individuals who have the appropriate security clearance required to perform their duties. Access should not be granted solely based on a request or demand for the information.

4.5 Protecting access rights

The Access to Information Act grants all individuals and corporations in Canada the right to access federal records that are under the control of federal government institutions, with a few limited exemptions. The act also makes it an offence to destroy, alter, falsify or conceal a government record, or to direct anyone to do so, with the intent of denying a person access to their personal information or information collected by the TBS.

Under the Privacy Act, individuals in Canada also have the right to access their own personal information in federal government records under the control of a federal institution. This right is subject to certain exceptions outlined in the act.

If you have any questions about your rights or obligations as a TBS employee, contact TBS’s Access to Information and Privacy unit by email at atip.aiprp@tbs-sct.gc.ca or TBS’s Privacy unit by email at privacy.vieprivee@tbs-sct.gc.ca. For more information, see Access to Information and Privacy on the TBS InfoSite.

5. Social media

Social media increasingly blurs the boundaries between our work and our personal lives. While what you do on your own time is generally a personal decision, you should also be aware of the risks, associated with the use of social media.

Your duty of loyalty requires you to treat all information shared on social media as if it is immediately available to the public. Even a casual comment can potentially undermine TBS’s ability to fulfill its mandate, impact your effectiveness as an employee, or undermine or jeopardize the perception of the impartiality, integrity and neutrality of the federal public service, as online information can be taken out of context, be widely distributed and remain permanent.

Social media posts, including re-posting content, should also demonstrate respect and mindfulness of the feelings of others. For example:

  • It is unacceptable to share inappropriate comments (such as negative, inflammatory or accusatory statements or the use of inappropriate language) to an account associated with work.
  • It is unacceptable to engage in online bullying and harassment.
  • It is unacceptable to criticize co-workers on social media, even if you used a fictitious name; an outside reader may not know who the individual is, but the individual can easily be identified by fellow employees.

It is important to remember that social media and networking sites (whether personal or professional) are accessible to a broad and often unintended audience, regardless of your privacy settings.

Finally, you should never share protected, classified or government information that has not been made public or intentionally spread misinformation or disinformation through social media, public forums or other means.

For more information on proper conduct in using social media, refer to Guidance for Public Servants on their Personal Use of Social Media and the Guideline on Acceptable Network and Device Use.

6. Conflict of interest and post-employment

In this section

6.1 Directive on Conflict of Interest

All TBS employees are subject to the Directive on Conflict of Interest. The directive provides direction to employees and designated senior officials to enable them to minimize risks associated with conflict of interest and conflict of duties situations, with the goal of upholding the values and ethics of the public sector and the public interest.Footnote 2

Section A.2.2.2 of the Directive on Conflict of Interest sets out the requirements for public servants for preventing and dealing with conflict of interest situations. These requirements are grounded in and serve to uphold the values contained in the Values and Ethics Code for the Public Sector and the TBS Code of Conduct.

By upholding these ethical standards, we preserve and enhance public confidence in the honesty, fairness and integrity of the public service. A public servant who does not comply with the requirements set out in the directive’s Appendix A may be subject to disciplinary measures, up to and including termination of employment.

6.2 Definition of conflict of interest

The Policy on People Management defines a conflict of interest as “a situation, whether real, apparent or potential, in which the person employed has private interests that could influence the performance of their official duties and responsibilities or in which the person employed uses their office for personal gain.”

A real conflict of interest exists at the present time; an apparent conflict of interest could be perceived by a reasonable observer to exist, whether or not it is the case; and a potential conflict of interest could reasonably be foreseen to exist in the future.

Conflict of interest is not limited to financial transactions or the transfer of economic benefits. Although financial matters are important, conflicts can arise in any area of activity that affects the perceived objectivity of the public service. Given the widespread use of information technology, public servants should be especially vigilant about real, apparent or potential conflicts of interest that may arise when they post online messages and information, for example, when posting information about, or the promotion or criticism of, a person, product, company or service.

In addition to the requirements outlined in Appendix A of the Directive on Conflict of Interest, you should also follow any specific conduct requirements outlined in the statutes governing the department and the ethical rules of your profession (for example, procurement expert, mediator, lawyer, auditor).

Below are some examples of conflicts of interest:

  • You have additional employment, such as consulting services, alongside your official duties at TBS and you are using government information, assets, equipment, workspaces or work hours for tasks related to your outside employment
  • You are managing a file or an assignment (for example, an audit, investigation, appeal, mediation or Treasury Board submission) that involves a family member or a friend as the client
  • You have personal ties with a bidder in a procurement process
  • You are in a position to make or influence a decision regarding funding, contracts, processes, or a grant and contributions project that involves a family member or a friend
  • Your family members or friends are candidates in a staffing process in which you are part of the selection board or assessment committee
  • You are a member of the board of directors for a non-profit organization with which you have official dealings in your role at TBS

These examples do not cover all possible situations. When in doubt, you should seek guidance from your supervisor or TBS’s Values and Ethics Office.

6.3 General responsibilities and duties under the Directive on Conflict of Interest

Your general responsibilities and duties under the Directive on Conflict of Interest include:

Conflict of interest management

  • taking all possible steps to recognize, prevent, report and resolve any real, apparent or potential conflicts of interest between your official responsibilities and duties and your private affairs or interests
  • ensuring that any real, apparent or potential conflict that arises between your private activities and your official responsibilities as a public servant is resolved in the public interest
  • avoiding private interests that could be unduly affected by government actions in which you participate, have knowledge of, or have information about, unless otherwise permitted by Appendix A: Mandatory Procedures for Preventing and Resolving Conflict of Interest Situations of the Directive on Conflict of Interest

Use of government resources

  • refraining from the direct or indirect use of, or allowing the direct or indirect use of, government property of any kind, including property leased to the government, for anything other than officially approved activities—government property includes but is not limited to equipment, documents, resources, networks and premises
  • not assisting private entities or persons in their dealings with the Government of Canada where doing so would result in preferential treatment of the entities, people, yourself or your family
  • not interfering in the dealings of private entities or people with the government in order to inappropriately influence the outcome

Impartiality and ethical conduct

  • maintaining the public service’s impartiality and not engaging in any outside or political activities that impair, or could be seen to impair, your ability to perform your duties in an objective or impartial manner
  • unknowingly taking advantage of, or benefiting from, information that is obtained in the course of your duties that is not available to the general public

6.4 Requirements for identifying, preventing, reporting and resolving conflict of interest

Regardless of your level or position, you are required to report in writing all outside employment, activities, assets, liabilities and interests by way of a Conflict of Interest Declaration. It must be completed and submitted within 60 days of your initial appointment or any subsequent appointment, transfer or deployment. TBS’s Values and Ethics Office will review the information submitted and determine whether a conflict of interest exists. If so, mitigation measures and recommendations will be provided to address the conflict in accordance with TBS’s procedures.

You are also required to review your obligations under the Values and Ethics Code for the Public Sector, the TBS Code of Conduct and the Directive on Conflict of Interest on a regular basis and whenever a significant change occurs in your personal affairs, interests or official duties. If a real, apparent or potential conflict of interest exists, you must submit a Conflict of Interest Declaration in a timely manner for TBS’s Values and Ethics Office to review.

When negotiating financial arrangements with outside parties on behalf of TBS, you must comply with the requirements of:

If you are not sure, you should immediately report the situation to your supervisor to seek advice or direction on how to proceed.

6.4.1 Assets and liabilities

You are required to manage your assets and liabilities, with consideration given to the nature of your official duties and responsibilities, and the characteristics of those assets and liabilities. If you identify any real, apparent or potential conflict of interest between your duties and your assets or liabilities (such as whether there is a link between your assets and liabilities, and files, and the contracts you manage in your official role), you must report it to TBS’s Values and Ethics Office by promptly submitting a Conflict of Interest Declaration.

If it is determined that your assets or liabilities create a conflict of interest with your official duties, you may be required to adjust your responsibilities, sell or dispose of certain assets or liabilities, or take other steps to resolve the conflict. You are not allowed to sell or transfer assets or liabilities to family members or others in an effort to bypass these compliance requirements.

The types of assets that should be reported and the procedures for reporting and managing such assets are set out in Appendix B: Standard on Preventing and Resolving Financial Conflicts of Interest of the Directive on Conflict of Interest.

6.4.2 Outside employment or business

You may engage in outside employment or business of the public service unless it is likely to create a real, apparent or potential conflict of interest or undermine the impartiality of the public service or your objectivity. That said, you must accurately report, to the best of your knowledge, and without delay, all outside employment and business in a Conflict of Interest Declaration.

You must receive written approval from the Secretary of the Treasury Board or the delegated authority before entering into a contractual arrangement with the Government of Canada in which you directly or indirectly receive a benefit or income. To do so, you must promptly report your contractual arrangement plans by submitting a Conflict of Interest Declaration.

Where it is determined that your situation is at risk of a real, apparent or potential conflict of interest or conflict of duties, you may be required to modify or terminate your outside employment, business or contractual arrangement.

6.4.3 Outside activity

Employees are required to report fully and without delay any outside activity that might give rise to a real, apparent or potential conflict of interest or conflict of duties in a Conflict of Interest Declaration for analysis.

Where it is determined that your situation is at risk of a real, apparent or potential conflict of interest or conflict of duties, you may be required to modify or terminate your outside employment, business or contractual arrangement.

6.4.4 Political activities

The Public Service Employment Act allows you to participate in political activities as long as your involvement does not affect, or appear to affect, your ability to perform your duties in a politically impartial manner.

“Political activity” is defined in Part 7: Political Activities of the Public Service Employment Act as:

“(a) carrying on any activity in support of, within or in opposition to a political party;

“(b) carrying on any activity in support of or in opposition to a candidate before or during an election period; or

“(c) seeking nomination as or being a candidate in an election before or during the election period.”

Before deciding to engage in a political activity, you should consider:

  • the nature of the activity
  • the nature of your duties
  • the level of visibility of your position
  • your personal or professional visibility in your community

The appropriateness of engaging in political activities is assessed on a case-by-case basis and on the specific circumstances of the employee. Voting in an election is always allowed, as it is a right and is considered a permissible political activity.

Under the Public Service Employment Act, the Public Service Commission of Canada (PSC) may investigate any allegation of improper political activity by a federal public service employee. If the investigation determines that there was an improper political activity, the PSC may take any corrective action deemed appropriate.

Employees seeking to be a candidate

Public servants are required to seek and obtain permission from the PSC to seek a nomination or to be a candidate in a federal, provincial, territorial or municipal election, in accordance with Part 7: Political Activities of the Public Service Employment Act. If you are seeking to be a candidate in an election at any level of government, you are required to contact your organization’s Designated Political Activities Representative and follow the PSC’s procedure. Remember, as a federal public servant, you must obtain the PSC’s permission before publicly declaring your intention. For more information, refer to the PSC’s web page on political candidacy.

Employees seeking to engage in non-candidacy political activity

If you are considering involvement in a political activity, you should seek the advice of your supervisor, TBS’s Values and Ethics Office, Designated Political Activities Representatives  or the PSC before taking up such activities.

Examples of non-candidacy political activities include:

  • volunteering or fundraising for a candidate or a political party
  • displaying political material such as a picture, sticker or button, or placing a sign on your lawn in support of or in opposition to a candidate or a political party
  • attending events, meetings, conventions or other political gatherings in support of or in opposition to a candidate or a political party
  • developing promotional material such as campaign speeches, slogans and pamphlets for a candidate or a political party
  • using blogs, social networking sites, a personal website or video-sharing to express personal views in support of or in opposition to a candidate or a political party

To ensure that the risk of political impartiality is mitigated, there must be a clear distinction or separation between your duties as a public servant and your political activities.

It is strongly recommended that you also complete the PSC’s Political Activities Self-Assessment Tool. This tool is intended to help you make reasonable decisions about your involvement in political activities and the impact on your ability to perform your duties and responsibilities in a politically impartial manner. Your Designated Political Activities Representative should also be contacted for advice.

Before engaging in non‑candidacy political activities that could impair or be perceived by others as impairing your ability to perform your duties in a politically impartial manner, you should complete a Conflict of Interest Declaration.

Non-partisan activities in connection with elections
Non-partisan activities related to elections are activities or employment that are connected to elections but are not in support of a specific party or candidate.

Examples of non-partisan activities related to elections include:

  • collecting ballots on election day
  • compiling and releasing election results
  • reviewing, producing and storing election documents and forms

Before engaging in non-partisan activities that could constitute a conflict of interest, you should complete a Conflict of Interest Declaration.

6.4.5 Gifts, hospitality and other benefits

You must not accept any gifts, hospitality or other benefits that could influence your objectivity in performing your official duties or place you under an obligation to the donor. Obligation to the donor refers to a situation where a person feels pressured to return a favor or provide special treatment to someone who has given them a gift, hospitality, and other benefits. Benefits could include receiving free or discounted access to sporting or cultural events, travel or conferences.

Accepting gifts, hospitality or other benefits is permissible if they:

  • are infrequent and of minimal value
  • are within the normal standards of courtesy or protocol
  • arise out of activities or events related to your official duties and responsibilities
  • do not compromise or appear to compromise your integrity or TBS’s integrity

Infrequent gifts of minimal value, such as desk items, mugs, caps, cookies, chocolates and jam, are generally acceptable unless explicitly prohibited by your supervisor.

If you are unable to decline gifts, hospitality or other benefits that do not meet the principles outlined above, or if you believe accepting certain hospitality (such as a gift from a foreign delegate) would benefit TBS, you must obtain written direction from a delegated authority. In such cases, you are required to complete a Conflict of Interest Declaration.

The following types of gifts are never acceptable and should be declined and returned with an explanation:

  • money or cash equivalents (for example, gift cards or certificates)
  • travel or overnight accommodations
  • free or discounted admission to sporting and cultural events, travel or conferences
  • expensive gifts (gifts that are not of minimal value as illustrated in the examples above)
  • any gift or favour received during a bidding process (including gifts of minimal value)

Note: You may accept and benefit from a standard corporate discount if it is advertised to the public or to all government employees, such as a fitness centre or automobile insurer, as long as there is no real, apparent or potential conflict of interest that affects your objectivity in carrying out your official duties and there is no expectation on the part of the company or organization to receive something in return.

If you are unsure, you should immediately consult your supervisor or TBS’s Values and Ethics Office.

6.4.6 Solicitation and fundraising

Government-supported charitable activities

You may not solicit gifts, hospitality, other benefits, or transfers of economic value from a person, group or organization in the private sector that has dealings with the government, with the exception of fundraising for officially supported activities, such as the Government of Canada Workplace Charitable Campaign.

Before soliciting donations, prizes or contributions for any group or activity, you should obtain written authorization from the Secretary of the Treasury Board or the department’s delegated authority.

Charitable activities not officially supported by the government

Fundraising or soliciting support for charitable activities not officially supported by the Government of Canada requires both the support of TBS’s Values and Ethics Office and written authorization from the Secretary or the delegated authority.

Similarly, if someone outside the department, such as a person or organization that TBS has worked with, is working with or might work with in the future, offers a benefit (such as money for an event or equipment), you should:

  • submit a Conflict of Interest Declaration to assess whether a real, apparent or potential conflict of interest exists
  • seek guidance and recommendations from TBS’s Values and Ethics Office
  • obtain written approval from the Secretary or the delegated authority before accepting any such benefit

If a conflict of interest or obligation to the donor is identified, the Secretary of the Treasury Board or the delegated authority may require that the activity be modified or terminated.Footnote 3

Non-charitable activities

Fundraising or soliciting for non-charitable initiatives within the workplace (for example, supporting children’s sports teams, selling items, posting signs or offers) requires management approval. Once approved, the soliciting activity should be conducted in a respectful manner.

Workplace soliciting and fundraising activities:

  • should not disrupt other employees
  • should not take place during work hours but can occur during breaks or lunch hours
  • should remain passive, such as displaying an approved poster (without directly asking employees for contributions)
  • should not use government assets or resources (for example, departmental email, photocopier) unless authorized by management
  • should avoid the perception of preferential treatment (for example, favouring a specific organization or business with which TBS has official dealings)
  • should not pressure employees who choose not to participate, or offer preferential treatment for participants or disadvantage those who do not participate

6.4.7 Lotteries and games of chance

Asking colleagues to participate in purchasing a lottery ticket, such as Lotto 6/49 or Lotto Max, is allowed in the workplace. However, internally organized lotteries and games of chance are not permitted unless you or the organizers have obtained authorization and a licence from the provincial authorities responsible for lotteries.

6.4.8 Preferential treatment

You are responsible for demonstrating objectivity and impartiality in your official duties and decision-making, whether it involves staffing, financial awards or penalties to external parties, transfer payments, program operations, or any other responsibilities.

Examples of such conflicts include but are not limited to the following:

  • contracting processes
  • administrative processes that involve staffing, finances, procurement or other sensitive information
  • decision-making situations where your actions could significantly impact the career, position or finances of relatives or friends in their dealings with TBS

You are prohibited from granting or offering special assistance, preferential treatment or advantages to family, friends, or any other person or entity, including those already dealing with the government or TBS, unless you have received written approval from your supervisor.

It is important to note that excellence in service should be encouraged and not seen as preferential treatment. In addition, you should not allow personal bias or hostility to disadvantage any individual or entity dealing with the Government of Canada. Providing publicly accessible information (for example, a brochure posted on the departmental website) is not considered preferential treatment.

Supervision

Direct or indirect supervision of relatives or friends by management at any level within TBS should be avoided whenever possible. As a supervisor, you should not be involved in any human-resources-related matters for individuals with whom you have a personal relationship, whether it’s a relative or friend.

If such a situation arises, both the supervisor and the employee should complete and submit a Conflict of Interest Declaration.

If the designated authority determines there is a real, apparent or potential conflict of interest or conflict of duties, mitigation measures may be implemented to reduce the risk. In the meantime, supervisors should take immediate steps to address and mitigate the conflict of interest risk in the workplace whenever possible. Mitigation measures should ensure that supervision remains objective and neutral and is perceived as such. Depending on the specifics of the situation, the measures may involve removing the employee from the supervisor’s line of supervision as a potential solution.

Staffing decisions

The principles of merit, non-partisanship, fairness, transparency, access and representation must be upheld in all TBS staffing actions, including TBS’s requirements regarding family or personal relationships.

You must not participate in or influence the promotion, assessment, selection or appointment of relatives or friends in any staffing action or process. In addition, you must avoid processing or handling any applications, files or accounts related to yourself or individuals with whom you have a personal relationship.

When employees propose a candidate, hiring managers must perform their due diligence to check for any potential relationships between the employee and the proposed candidate to ensure there is no conflict of interest. Employees should also refrain from actively promoting candidates with whom they have a personal relationship.

If you learn that a relative or friend is a candidate in any staffing action in which you are involved, you must immediately recuse yourself, inform your supervisor and the staffing advisor, and complete a Conflict of Interest Declaration.

You must also avoid bias, whether it is to favour or to hinder any one group or individual.

6.5 Obligations when leaving the public service

6.5.1 Before leaving your public service employment

As a public servant, you have a responsibility to minimize the possibility of real, apparent or potential conflict of interest between your most recent responsibilities within the federal public service and your subsequent employment outside the public service.

A Conflict of Interest Declaration should be completed and submitted before leaving the department for all intended future employment and activity that might give rise to a real, apparent or potential conflict of interest with respect to your most recent official duties and responsibilities.

In addition, you are prohibited from taking or sharing documents and any protected, classified or confidential information that has not been made public or not intended for the public that you acquired during your public service employment. Neither may you use any information gathered during your employment for personal purposes or benefit.

6.5.2 Post-employment limitation period for public servants in designated positions

The limitation period for public servants applies to employees in designated positions. At TBS, the designated positions are executives (EX), EX minus one, and EX minus two categories and their equivalents. The Secretary or the delegated authority may also designate additional positions. TBS’s Values and Ethics Office maintains a list of these positions.Footnote 4

If you are in a designated position, you are subject to a one-year limitation period after leaving your public service employment. Before your departure and during this one-year period, you must report to TBS’s Values and Ethics Office any firm offers of employment or proposed activities outside the public service that could create a real, apparent or potential conflict of interest with your public service duties. You must also immediately disclose the acceptance of any such offer. In addition, during this one-year period, and unless you have authorization from the Secretary, you may not:

  • accept an appointment to a board of directors of, or employment with, outside entities or individuals with which they had significant official dealings, either directly or through their subordinates, in the year immediately prior to leaving their employment in the public service
  • make representations on behalf of entities or individuals outside of the public service to any government organization with which they had significant official dealings, either directly or through their subordinates, in the year immediately prior to leaving their employment in the public serviceFootnote 5
  • give advice to their clients or any new employer by using information that is not publicly available concerning the programs or policies of the department or organization with which they were employed or with which they had a direct and substantial relationship

6.5.3 Waiver or reduction of limitation period

As a public servant or former public servant, you may request a written waiver or reduction of the limitation period from the Secretary. To support your request, you should provide sufficient information to help the Secretary determine whether the waiver or reduction should be granted. TBS’s Values and Ethics Office will review the information to assess whether granting the waiver or reduction is in the public interest and, if so, will provide recommendations for the Secretary’s consideration.

7. Breach of the codes and discipline

A breach of the Values and Ethics Code for the Public Sector and TBS Code of Conduct or any of the related laws, policies or procedures may lead to administrative or disciplinary measures being taken, up to and including termination of employment. Adherence to the public sector values and the expected behaviour is a condition of employment for all TBS employees.

Discipline is intended to be corrective rather than punitive. Its purpose is to motivate employees to uphold the rules and standards of conduct that are desirable or necessary to achieve the goals and objectives of the organization. In increasing order of severity, disciplinary measures are as follows:

  • oral reprimand
  • written reprimand
  • suspension or financial penalty
  • demotion
  • termination of employment

The level of discipline will depend on the severity of the breach and the circumstances surrounding it, as well as any mitigating or aggravating factors. Discipline is normally progressive, but a more serious offence, even a first offence, can lead to greater discipline and the immediate termination of employment.

If you have information that could indicate a serious breach of the Values and Ethics Code for the Public Sector and TBS Code of Conduct or other forms of wrongdoing, as set out in section 8 of the Public Servants Disclosure Protection Act, you can, in accordance with sections 12 and 13 of the act, bring the matter, in confidence and without fear of reprisal, to the attention of your immediate supervisor, TBS's Senior Officer for Disclosure or the Public Sector Integrity Commissioner.

Consequences of non-compliance with the Directive on Conflict of Interest may include administrative or disciplinary measures or any other measures allowed by the Financial Administration Act that the department may determine as appropriate.Footnote 6

Glossary

Administrative measure (Mesure administrative)
An administrative measure is generally aimed at managing or organizing processes, systems, or actions to ensure that procedures and policies are followed properly. It could include reassigning tasks, providing additional training, or making procedural adjustments to improve workflow or policy implementation.
Conflict of interest (Conflit d’intérêts)
A situation, whether real, apparent or potential, in which the person employed has private interests that could influence the performance of their official duties and responsibilities or in which the person employed uses their office for personal gain.
Conflict of interest declaration (Déclaration de conflit d’intérêts)
A declaration form completed by employees of the department regarding any real, apparent or potential conflict of interest, conflict of duties, and all cases of outside employment.
Deputy head (Administrateur générale ou administratrice générale)
For the purposes of the TBS Code of Conduct, deputy head refers to the Secretary or their delegates.
Delegated authority (Autorités déléguées)
The individuals delegated by the Secretary, through the Human Resources Delegation Instrument.
Disciplinary measure (Mesure disciplinaire)
A disciplinary measure is intended to correct inappropriate behaviour, misconduct, or failure to comply with rules or regulations. It usually involves actions such as warnings, reprimands, suspension, demotion or even dismissal, depending on the severity of the misconduct.
Persons employed, employees, public servants (Personnes employées, employés, personnel, effectifs, fonctionnaires)

In the TBS Code of Conduct, the term “employees” is primarily used, whereas “public servants” is used when quoting the language used in acts, regulations, directives and other authorities. Therefore, the terms “employees” and “public servants” should be understood as:

  • persons employed as noted in Appendix D: Definitions of the Policy on People Management
  • individuals governed by the TBS Code of Conduct
Ethics (Éthique)
The dimension of human thought and behaviour that is guided by standards and principles of right conduct. Ethics involve a commitment to do the right thing.
Family member (Membre de la famille)
Includes extended family (that is, beyond the nuclear family) such as but not limited to an employee’s parents, step-parent, foster parent, sibling, spouse, common-law partner, child, stepchild, ward, foster child, son-in-law, daughter-in-law, father-in-law, mother-in-law, brother-in-law, sister-in-law, grandparent, grandchild, uncle, aunt, nephew, niece and cousin.
Government property (Biens du gouvernement)

Physical assets include but are not limited to buildings, vehicles, facilities, office supplies and ergonomic equipment (including items purchased for specific employees).

Information and data include but are not limited to information held by the department, files, documents, data banks and intellectual property.

Technology and equipment include but are not limited to computers, laptops, USB (universal serial bus) drives, printers, photocopiers, telephones, mobile devices, electronic networks, software and video equipment.

Identification and financial instruments include but are not limited to identification cards, taxi chits, calling cards, negotiable instruments and government credit cards (including those used for travel).

Protected disclosure (Divulgation protégée)

As defined by the Public Servants Disclosure Protection Act, a protected disclosure that is made in good faith and that is made by a public servant:

“(a) in accordance with this Act;

“(b) in the course of a parliamentary proceeding;

“(c) in the course of a procedure established under any other Act of Parliament; or

“(d) when lawfully required to do so.”

Public sector (Secteur public)

As defined by the Public Servants Disclosure Protection Act, means:

“(a) the departments named in Schedule I to the Financial Administration Act and the other portions of the federal public administration named in Schedules I.1 to V of that Act; and

“(b) the Crown corporations and the other public bodies set out in Schedule I.”

The public sector does not include the Canadian Armed Forces, the Canadian Security Intelligence Service or Communications Security Establishment Canada, which are subject to separate requirements under the act.

Record (Document)
As defined by the Access to Information Act, means any documentary material, regardless of medium or form.
Reprisal (Représailles)

As defined by the Public Servants Disclosure Protection Act, a reprisal is any of the following actions taken against a public servant:

“(a) a disciplinary measure;

“(b) the demotion of the public servant;

“(c) the termination of employment of the public servant, including, in the case of a member of the Royal Canadian Mounted Police, a discharge or dismissal;

“(d) any measure that adversely affects the employment or working conditions of the public servant; and

“(e) a threat to take any of the measures referred to in any of the paragraphs from (a) to (d).”

Under the Public Servants Disclosure Protection Act, such actions are considered reprisals if they are taken because the public servant made a protected disclosure or, in good faith, cooperated in either an investigation into a disclosure or an investigation ordered under section 33 of the act.

Social media (Médias sociaux)
Platforms that engage users to participate, comment, and create content using electronic communication to share content and information with other users online.
Supervisor (Superviseur ou superviseure)
Individuals who have one or more employees under their supervision and who are responsible for assigning work, hiring, and approving leaves and similar tasks (for example, directors, managers, team leaders). For the purposes of the TBS Code of Conduct, a supervisor and immediate supervisor are the same person.
Values (Valeurs)
Enduring beliefs that influence opinions, actions, choices and decisions.
Wrongdoing (Acte répréhensible)
As defined in section 8 of the Public Servants Disclosure Protection Act.

Appendix: duties and obligations

In this section

Secretary

The Secretary has specific responsibilities under the Public Servants Disclosure Protection Act, including establishing a code of conduct for the department and an overall responsibility for fostering a positive culture of values and ethics in the department.

The Secretary ensures that:

  • employees are aware of their obligations under the TBS Code of Conduct and the Values and Ethics Code for the Public Sector
  • employees can obtain appropriate advice within the department on ethical issues, including possible conflicts of interest
  • the Values and Ethics Code for the Public Sector, the TBS Code of Conduct and internal disclosure procedures are effectively implemented and are regularly monitored and evaluated within the department
  • the non-partisan provision of the department’s programs and services is upheld

The Secretary is subject to the TBS Code of Conduct, the Values and Ethics Code for the Public Sector and the Conflict of Interest Act.

Senior Officer for Disclosure

The Senior Officer for Disclosure helps promote a positive environment for disclosing wrongdoing and deals with disclosures of wrongdoing made by TBS employees. The designated official is responsible for supporting the Secretary in meeting the requirements of the Public Servants Disclosure Protection Act.

Treasury Board of Canada Secretariat’s Office of the Chief Human Resources Officer

In support of the Treasury Board President’s responsibilities under section 4 of the Public Servants Disclosure Protection Act, the Office of the Chief Human Resources Officer (OCHRO) is responsible for promoting ethical practices in the public sector.Footnote 7 OCHRO will work with all relevant partner organizations to implement and promote the Values and Ethics Code for the Public Sector and will provide advice to chief executives and designated departmental officials with respect to its interpretation.

The Chief Human Resources Officer may issue directives, standards and guidelines related to the Values and Ethics Code for the Public Sector.

OCHRO will monitor the implementation of the Values and Ethics Code for the Public Sector in organizations that have a mandate to assess whether the stated objectives have been achieved.

Treasury Board of Canada Secretariat’s Values and Ethics Office

TBS’s Values and Ethics team supports TBS’s Senior Official for the Prevention of Conflict of Interest and Conflict of Duties. The team is responsible for providing advice and recommendations to all employees regarding the TBS Code of Conduct. They are also responsible for providing guidance on ethical questions and concerns as they arise.

Managers and executives

In the context of this code, and according to the Values and Ethics Code for the Public Sector, public servants who are also managers or executives are in a position of influence and authority that gives them a particular responsibility to exemplify the values of the public sector.

Their actions, decisions and interactions set a strong example and speak louder than any written code. They influence the workplace culture and environment, establishing the foundation for a healthy and ethical work environment in our hybrid model.

In addition, they are expected to demonstrate the key leadership competencies and executives are also expected to abide and live by the “Everyday Commitment.”

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2025-08-07