Internal Audit Report - Audit of Values and Ethics

March 2014

Table of Contents

• 1. Executive Summary
• 2. Background
• 3. Audit Objectives
• 4. Audit Approach
• 5. Audit Findings
  • 5.1 Establishing a Values and Ethics Framework at INFC
  • 5.2 Integrating the Values and Ethics Framework into INFC Culture
• 6. Conclusion
• 7. Statement of Conformance
• 8. Management Response and Action Plan
• Appendix A: Audit Criteria

1 EXECUTIVE SUMMARY

Introduction

The Government of Canada is committed to promoting ethical practices in the Public Sector. Legislation such as the Public Servants' Disclosure Protection Act and Treasury Board policy instruments such as the Values and Ethics Code for the Public Sector and Policy on Conflict of Interest and Post-Employment support and guide Public Sector employees as they fulfill their roles and responsibilities.

In April 2012, the Infrastructure Canada (INFC) Code of Conduct and INFC Conflict of Interest and Post-Employment Policy were launched to complement the legislative and Treasury Board policy instruments. In addition, a Values and Ethics framework was introduced that built upon the policy suite foundation and included a number of initiatives that were established in order to foster the integration of Values and Ethics into the day-to-day work of employees within the Department.

Audit Objectives and Scope

The audit objective was to assess the implementation and effectiveness of Infrastructure Canada's Values and Ethics framework.

The audit scope focused on INFC's compliance with key federal legislative and Treasury Board policy requirements related to Values and Ethics. In addition, the audit assessed INFC's Values and Ethics framework using indicators derived from a Values and Ethics maturity model published by the Institute of Internal Auditors.

The conduct of the audit employed various techniques. These included conducting interviews, using an employee questionnaire to obtain information, analyzing the results of the employee questionnaire, and examining documentation such as policies and procedures, departmental committee minutes, employee acknowledgements, and employee letters of offer.

Conclusion

Overall, Infrastructure Canada's Values and Ethics framework was generally well implemented and operated effectively. Opportunities to improve the effectiveness of the Values and Ethics framework include the following:

• Ensuring that all employees confirm that they have read and will comply with the Treasury Board and departmental codes of conduct and policies related to conflicts of interest and post-employment;
• Revising specific wording of some sections of the INFC Conflict of Interest and Post-Employment policy to ensure that it complements the Treasury Board policy instrument;
• Strengthening the processes in place to carry out the function of the Integrity Officer;
• Strengthening performance measures and formalizing the monitoring of the implementation of the Values and Ethics framework;
• Updating the information available to employees on the intranet; and
• Assessing options for better integrating the Values and Ethics framework into the day to-day work of INFC employees.

Management is in agreement with the audit findings and recommendations. Management has developed action plans to address the recommendations which have been included in the report.

2 BACKGROUND

The Government of Canada is committed to promoting ethical practices in the Public Sector. Legislation such as the Public Servants' Disclosure Protection Act and Treasury Board policy instruments such as the Values and Ethics Code for the Public Sector and Policy on Conflict of Interest and Post-Employment support and guide Public Sector employees as they fulfill their roles and responsibilities.

The Public Servants' Disclosure Protection Act provides guidance to public sector employees on the processes that are in place to support them if they have identified potential wrongdoings in their place of work. This includes methods to report the information, and to protect themselves from acts of reprisal. It recognizes the role of public servants in enhancing and maintaining public trust in the institutions of government.

The Values and Ethics Code for the Public Sector outlines the five values that guide public sector behaviours. Respect for Democracy, Respect for People, Integrity, Stewardship, and Excellence are the principles that underlie the roles and responsibilities of Chief Executives (equivalent to a Deputy Minister), Senior Disclosure Officers, and public sector employees. The Treasury Board Policy on Conflict of Interest and Post-Employment elaborates on the identification and prevention of conflicts of interests for public sector employees during their careers and post-employment.

In April 2012, the Department launched the INFC Code of Conduct, the INFC Conflict of Interest and Post Employment Policy and the INFC Fraud Policy. These three policy instruments make up the departmental Values and Ethics policy suite and provide guidance to employees on how to conduct themselves in an ethical manner and how to address specific situations that may occur in the workplace.

The INFC Code of Conduct outlines the values and behaviours that are expected of employees. It also supports and complements the Treasury Board Values and Ethics Code for the Public Sector. The INFC Conflict of Interest and Post Employment Policy objectives are, among other things, to ensure decisions are made in a manner that upholds the public interest and to facilitate ethical decision-making. Finally, the INFC Fraud Policy's objective is to minimize the risk of fraud being perpetrated against the Department by ensuring that effective fraud risk management practices are in place and all stakeholders have a clear understanding of their roles and responsibilities in this area.

Values and Ethics at INFC is more than a policy suite. The framework also includes roles and responsibilities for key positions within the Department such as the Values and Ethics Champion who is supported by a Value and Ethics Officer; the Integrity Officer who acts as the departmental Senior Disclosure Officer; and the Values and Ethics Committee which includes representatives from across the Department. It includes concrete initiatives aimed at educating employees and providing them with training, support and guidance. Finally, the framework promotes related departmental initiatives such as conflict resolution and harassment prevention.

3 AUDIT OBJECTIVES

The audit objective was to assess the implementation and effectiveness of Infrastructure Canada's Values and Ethics framework.

The audit scope focused on INFC's compliance with key federal legislative and Treasury Board policy requirements related to Values and Ethics. In addition, the audit assessed INFC's Values and Ethics framework using indicators derived from a Values and Ethics maturity model published by the Institute of Internal Auditors.

The period covered by the audit was from April 2, 2012 to November 30, 2013 with the exception of a questionnaire sent to all INFC employees that was administered in January 2014.

4 AUDIT APPROACH

The conduct of this audit was approved in the Risk-Based Audit Plan 2013–16. The examination phase began in December 2013 and was substantially completed in February 2014. The conduct of the audit employed various techniques. These included conducting interviews, using an employee questionnaire to obtain information, analyzing the results of the employee questionnaire, and examining documentation such as policies and procedures, departmental committee minutes, employee acknowledgements, and employee letters of offer.

The employee questionnaire which was sent to all INFC employees collected data on the level of employee knowledge related to the Values and Ethics framework. Questions encompassed elements of the policy suite, key positions, and described responsibilities. Our sample of 147 respondents is sufficient to project the entire population of 273 employees with a confidence interval of 5.5 percent, and a confidence level of 95 percent.

5 AUDIT FINDINGS

5.1 Establishing a Values and Ethics Framework at INFC

INFC senior management recognizes that while Values and Ethics are sometimes difficult to define, they are fundamental to the public service. The Department has prepared guidance on matters related to common workplace issues, conflicts of interest, post-employment practices, and fraud. This has been done to support employees in taking actions that demonstrate their commitment to Values and Ethics.

INFC is subject to legislative requirements under the Public Sector Disclosure Protection Act. The Act requires that the Deputy Minister establish a Code of Conduct that is applicable to the portion of the public sector for which they are responsible and that is consistent with the Code of Conduct established by the Treasury Board.

It was expected that the policy suite and accountability structure put in place to support the Values and Ethics framework would be developed, approved and operate as intended.

Detailed audit results in support of this conclusion are presented by theme.

Foundation for the Values and Ethics Framework

A Values and Ethics policy suite has been developed and is in place

An INFC Values and Ethics policy suite has been developed and implemented. The policy suite consists of three main documents — the INFC Code of Conduct, the INFC Conflict of Interest and Post Employment Policy and the INFC Fraud Policy. The establishment of these documents was in accordance with the Department's obligations under the various legislative and Treasury Board policy instruments related to Values and Ethics.

The policy suite was developed through consultations with all staff and senior management and forms the foundation for Values and Ethics initiatives within INFC. It was launched by the Deputy Minister in April 2012 through an e-mail sent to all staff.

The policy suite complemented Treasury Board policy instruments with some inconsistencies

INFC Code of Conduct. The INFC Code of Conduct is generally consistent with the Treasury Board Values and Ethics Code for the Public Sector. The departmental Code of Conduct considered the same values and provided for more detailed applications of those values. It also considered disclosures and the role of INFC's Integrity Officer.

INFC Conflict of Interest and Post-Employment Policy. INFC developed and approved an INFC specific Conflict of Interest and Post-Employment Policy. While this was not a requirement under the Treasury Board policy instrument, the departmental policy complements the Treasury Board policy in a number of ways.

However, the Treasury Board policy used stronger language than the INFC policy in a number of areas. For example, differences were observed in the wording related to employee roles and responsibilities, and some requirements for preventing and dealing with situations of conflict of interest. These differences in language changed the meaning of key policy elements from requirements to suggestions. Policy suggestions that only partially reflected Treasury Board requirements could lead to misunderstandings of how employees should implement the conflict of interest policy within INFC.

Recommendation 1. Infrastructure Canada should revise specific wording in some sections of the INFC Conflict of Interest and Post-Employment Policy to ensure that it complements Treasury Board policy instruments.

Management Response. Management accepts this recommendation. HR will review the INFC Conflict of Interest and Post-Employment Policy in order to modify wording in certain sections of the policy to ensure that the wording is similar to that mentioned in the TBS policy.

Accountabilities within the Values and Ethics Framework

Several governance bodies are accountable to oversee the Values and Ethics framework initiative. They include the Values and Ethics Committee and the People Management Committee.

An accountability structure is in place to support the Values and Ethics framework

The responsibility for the Values and Ethics portfolio falls under the purview of Human Resources, Security and Administration Directorate. In April 2012, a Values and Ethics Committee was established shortly after the launch of the policy suite. The Committee held its first meeting in August 2012. The Committee's mandate is to progress the implementation of the Values and Ethics framework within the Department. Each Branch has a representative on this committee. While the Committee is in place, the Terms of Reference have not yet been approved. The initial goal was to hold monthly meetings, however, due to departmental operational priorities, there have only been five meetings over the course of the past two years. As the Committee is the main forum for branch representatives to obtain information on Values and Ethics issues and raise concerns related to their specific areas within the organization, the formalization of the committee's Terms of Reference would enhance the Values and Ethics Framework.

In addition to the Values and Ethics Committee, the INFC People Management Committee also discussed Values and Ethics issues periodically. While the meeting minutes do not reflect these discussions, we were informed that the Values and Ethics Action Plan and progress towards achieving its objectives were discussed from time to time at committee meetings.

In general, key responsibilities have been defined in the policy suite

All INFC employees have responsibilities within the Values and Ethics framework and are accountable for their actions in accordance with the related legislation and Treasury Board policy instruments. In order to achieve accountability, there is a need to clearly define expectations and measure performance against these expectations.

It was expected that INFC defined employee's responsibilities within the Values and Ethics framework and had put processes in place to measure performance in achieving these responsibilities.

Employee responsibilities related to Values and Ethics are defined in the policy suite documentation — specifically the INFC Code of Conduct. Managers, supervisors, and executives have specific responsibilities in applying the various components of the Values and Ethics framework. These additional responsibilities include ensuring that employees under their responsibility receive and understand the Code of Conduct and have an opportunity to discuss it. Overall, 75 percent of managers, supervisors, and executives that responded to the audit questionnaire knew that they had additional responsibilities prescribed in the Code of Conduct.

The policy suite and departmental guidance documents outlined the specific responsibilities of key positions such as the Values and Ethics Champion and the Integrity Officer. However, the roles and responsibilities of the Values and Ethics Officer were not clearly defined in any document. The Values and Ethics Officer reports directly to the Director General of Human Resources.

The role of the Champion is to guide and support public servants in their professional activities. The Champion of Values and Ethics is responsible for encouraging dialogue on Values and Ethics, ensuring that mechanisms and assistance are in place to help public servants resolve issues related to the Code of Conduct, and providing advice to employees and the Deputy Minister.

The Integrity Officer is the senior manager responsible for providing INFC employees an avenue to discuss and submit allegations of wrongdoing in the workplace. The responsibilities of the Integrity Officer were clearly indicated in the INFC Code of Conduct.

During the audit period, an Integrity Officer was in place for INFC; however it was difficult to navigate the intranet to find the name or information on what INFC employees could expect if they wanted to share concerns with the Integrity Officer. Furthermore, there was no information regarding internal processes used by the Integrity Officer made available to INFC employees.

Recommendation 2. Infrastructure Canada should work with the Office of the Integrity Officer to enhance processes in place to carry out the function.

Management Response. Management accepts this recommendation. HR will work closely with the office of the Integrity Officer to clearly define roles and responsibilities and to ensure that liaising is done between both offices on a regular basis.

Monitoring and assessing the implementation of the Values and Ethics Framework

In keeping with good management practices, a Values and Ethics framework was developed and introduced, policies and procedures were put in place to support initiatives, committees and key positions were identified, and roles and responsibilities were established. Mechanisms were required to monitor the progress of implementing initiatives and measuring results. It was expected that INFC established goals and metrics to evaluate the implementation of the Values and Ethics framework.

Acknowledgement of the Code of Conduct and Policy on Conflict of Interest has not been received from all employees

The Treasury Board Values and Ethics Code for the Public Sector established that public sector employees must abide by the values and expectations described within the code. The Treasury Board Policy of Conflict of Interest and Post-Employment identified specific requirements that are a condition of employment for public sector employees.

Human Resources established one goal related to the Values and Ethics framework. The goal was to ensure that all employees read and committed to comply with the Treasury Board and departmental codes of conduct and conflicts of interest and post-employment policies.

Progress against this goal was monitored by using a tracking sheet to record the date an existing employee confirmed that they had read and would comply with the Treasury Board and departmental policy instruments. New employees that joined INFC after April 2, 2012 confirmed their compliance with the policies in their signed Letters of Offer. However, a few non-executive employees and almost all executive employees did not have a documented date of confirmation to support that they had fulfilled the condition of employment related to acknowledging the policies.

As a best practice from other federal departments, there is an opportunity for INFC to incorporate conflict of interest declarations into pre-existing employee processes such as the annual employee performance assessment process. Individual managers who are already charged with documenting employee assessments could require that employees complete annual affirmations that they are not currently in a conflict of interest position. This practice would increase employee knowledge of potential conflicts of interest and demonstrate the Department's commitment to Values and Ethics.

Recommendation 3. Infrastructure Canada should ensure that all employees confirm that they have read and will comply with the Treasury Board and departmental codes of conduct and policies related to conflicts of interest and post-employment.

Management Response. Management accepts this recommendation. HR will follow up with INFC employees who have not yet confirmed that they have read and will comply with the Codes and policies and will request that employees confirm that they have fulfilled this condition of employment. HR will continue to track progress towards this goal in the tracking sheet.

INFC has a Values and Ethics Action Plan in place

The Values and Ethics Champion led the development of a Values and Ethics Action Plan to support the implementation of the framework. The Values and Ethics Action Plan identifies a series of initiatives with associated milestones that had been developed to integrate the Values and Ethics framework into employee's day-to-day work. The plan was presented at a special INFC People Management Committee meeting held on October 31, 2012 where it was approved. While the agenda for this meeting stated that the action plan was to be approved, there were no meeting minutes to substantiate that approval took place. A senior official indicated that it had been approved on that date which was supported by details within the Values and Ethics Action Plan documentation.

There is also an opportunity to improve the milestones and measures that have been identified within the Values and Ethics Action Plan, as they were not always linked to objectives and in many cases the information provided was a summary of events that had already been performed.

Overall oversight and monitoring of the Values and Ethics Framework could be strengthened

The Treasury Board Values and Ethics Code for the Public Sector requires that the Department ensures that the Treasury Board and departmental codes of conduct and the departmental disclosure process are implemented effectively and that they are regularly monitored and evaluated. It was expected that there would be evidence to demonstrate that INFC was meeting these requirements.

INFC identified key positions within the Values and Ethics framework that were responsible to oversee implementation. The Values and Ethics Champion and the Values and Ethics Officer were primarily responsible to oversee the Values and Ethics framework. The Values and Ethics Committee was charged with oversight of the implementation of the Values and Ethics Action Plan. The INFC People Management Committee was responsible to approve the Values and Ethics Action Plan and to discuss the Values and Ethics framework on a quarterly basis.

In general, the Values and Ethics Officer updated the Values and Ethics Champion on a regular basis on the status of the framework and action plan initiatives within the Department. While this was done in the normal course of carrying out the function, there was no documentation related to these updates. The Values and Ethics Committee sometimes discussed specific elements of the Values and Ethics Action Plan that fell under their area of responsibility. The meeting minutes of the INFC People Management Committee did not demonstrate that the Values and Ethics framework was discussed on a quarterly basis. A senior official informed the audit team that discussions did take place periodically during the course of meetings; however, these discussions were not reflected in the high level minutes of the meetings.

In addition, about once a year the Director General of Human Resources makes a presentation to the Departmental Audit Committee on Values and Ethics. These presentations provide information on the various elements of the INFC Values and Ethics framework to the Deputy Minister, Associate Deputy Minister, and members of senior management in attendance.

Overall, there is an informal approach currently in use to monitor and oversee the implementation of the Values and Ethics framework within INFC. This is an area where the governance of the Values and Ethics framework could be improved by documenting committee meeting minutes related to the Values and Ethics framework and implementing a more formal monitoring system.

Recommendation 4. Infrastructure Canada should strengthen performance measures and formalize the monitoring of the implementation of the Values and Ethics framework.

Management Response. Management accepts this recommendation. The Values and Ethics Committee will begin developing the new Values and Ethics Action Plan and will ensure that all initiatives included in the new Action Plan include measurable outcomes. Additionally, INFC will put more structured approaches in place to ensure that the monitoring and oversight of the Action Plan is properly documented. The Values and Ethics Officer and Champion will continue to meet on a regular basis to review and discuss the values and ethics framework and a record of these meetings and discussions will be kept on file. The Values and Ethics Action Plan will continue to be presented at INFC's People Management Committee meeting on a quarterly basis and a record of this will be kept in the PMC minutes. Also, presentations on the values and ethics framework will continue to be made to the Departmental Audit Committee as requested.

5.2 Integrating the Values and Ethics Framework into INFC Culture

All employees have responsibilities related to exemplifying Public Service values. Managers and employees must strive to create and maintain a work environment that encourages dialogue on organizational values and the ethical dilemmas unique to their operations. To effectively integrate Values and Ethics into departmental practices, employees and managers must be familiar with their roles and responsibilities in implementing the Values and Ethics framework. This includes demonstrating Values and Ethics in personal behaviors, integrating Values and Ethics into unit practices, and fostering a climate of transparency, trust and respect within work units and in dealings with others.

It was expected that employees would be aware of the Values and Ethics framework and that training had been provided to all staff.

Detailed audit results in support of this conclusion are presented by theme.

Employee awareness and access to information

The integration of Values and Ethics into employee work culture is important in supporting the Department in meeting its objectives. One way in which Values and Ethics can be integrated is through the provision of information to employees on roles and responsibilities and key expectations. It was expected that INFC employees would have access to up-to-date and relevant information related to the Values and Ethics framework in place within the Department.

Information related to key responsibilities

INFC developed a website on its intranet to provide information to employees on the Values and Ethics framework. The main page describes the policy suite documents related to the framework and to which INFC employees are subject. It also identifies some key positions within INFC that employees could contact if they required more information — including the role of the Champion for Values and Ethics. It was observed that the links to the primary elements of the main page functioned correctly. This is important because almost all INFC employees knew that they could seek information and guidance on Values and Ethics issue from the intranet.

However, certain elements of the framework were difficult to find on the intranet site and some information was no longer accurate. For example, the name of the Integrity Officer that was in place during the time of the audit was difficult to find and the members of the Values and Ethics Committee could not be found. Furthermore, while the position of Values and Ethics Officer could be associated with a specific name, there was no information available to determine the name of the Values and Ethics Champion. At present, as employees may be unable to find the names of the key contacts on the intranet site, they may not be able to request information required to meet their responsibilities or to share concerns related to Values and Ethics.

Almost all employees knew that conflicts of interest required reporting as they arose and a significant majority could correctly identify a conflict of interest

The INFC Conflict of Interest and Post-Employment Policy available on the intranet provides descriptive definitions of what is meant by conflict of interest. In responding to the questionnaire, we found that while employees have knowledge about the main elements of the policy, some employees have gaps in their knowledge on how to apply it. Almost all respondents to our questionnaire knew that conflicts of interest were required to be reported as needed. In addition, while a significant majority of respondents correctly identified one of the definitions of conflict of interest provided in the policy, approximately one third of respondents could not correctly identify or were not sure that one of the definitions from the policy was a conflict of interest. This creates a situation where employees generally know they have to report a potential conflict of interest but may be unsure of what constitutes such a potential conflict.

Employee knowledge generally reflected the contents of information available on the intranet

The results of the questionnaire indicated that the majority of respondents could correctly identify the INFC Code of Conduct and the INFC Conflict of Interest and Post-Employment Policy as elements of the Values and Ethics policy suite. However, only half of the respondents correctly identified that the INFC Fraud Policy was part of the policy suite.

Employee knowledge of the Values and Ethics framework was consistent with information available on the intranet. This means that employees were knowledgeable about the aspects of the framework where information was available on the intranet site. Where information was either non-existent or outdated, employees had gaps in their knowledge. The best example of this relates to the role of the Integrity Officer. There was a lack of clarity between the role of the Integrity Officer and the role of Human Resources — particularly as it relates to investigating allegations of wrongdoing. Given the lack of clarity, employees may not know their responsibilities related to fraud prevention or who to contact if they have concerns about possible wrongdoing.

Recommendation 5. Infrastructure Canada should update the information available on the intranet site to ensure that it is current, relevant and accessible.

Management Response. Management accepts this recommendation and is committed to updating the values and ethics information on the Intranet. HR will review key values and ethics information currently posted on the website to ensure that the information is accurate and up-to-date and will make adjustments where necessary.

Values and Ethics training at INFC

When the Values and Ethics framework was introduced in April 2012, the issue of Values and Ethics went from being an implied behavior to an explicit responsibility. Specific obligations were established for key positions within the framework and for all employees. It also introduced new processes related to disclosure. It was expected that INFC would provide information and training to employees to build employee knowledge of the Values and Ethics framework. It was also expected that employees would be able to demonstrate their knowledge of the Values and Ethics framework.

Values and Ethics training has been provided to a significant portion of INFC employees

The Values and Ethics Committee had developed training materials to educate employees on the various elements of the Values and Ethics framework. This training was provided by members of the Values and Ethics committee and presented at Branch and Division level meetings. At the conclusion of the audit examination phase, training had been provided to most Branches within INFC. The Values and Ethics committee had planned to complete the training sessions for the two remaining Branches by the end of fiscal-year 2013-14.

Integration of Values and Ethics framework into employee activities

Values and Ethics shape the daily activities of employees. Their importance is emphasized by how they are incorporated into employee routines. It was expected that INFC would demonstrate its commitment to an ethical workplace by reinforcing the importance of values and ethics in departmental processes.

There is an opportunity to improve the integration of the Values and Ethics framework in departmental processes

There is an opportunity to have more formal and informal discussions on Values and Ethics within the Department. The results of the questionnaire demonstrated a disconnect between most managers, supervisors, and executives who indicated that Values and Ethics topics were discussed during most or few team meetings while a significant majority of INFC employees indicated that it was discussed at a few meetings or not at all.

INFC has several processes in place that allow management to influence employee behavior and performance. Annually, a performance agreement that establishes an individual's objectives and goals is signed by an employee and their manager or supervisor.

Team meetings occur on a much more frequent and informal basis than performance agreement discussions. These meetings provide employees with guidance on how to manage operational as well as administrative concerns. Team meetings provide an ideal setting for managers and employees to discuss the various elements of the Values and Ethics framework and how they apply to employees' daily activities. At present, the Department is not taking advantage of all the opportunities available to reinforce the importance of the Values and Ethics framework and its impact on the daily activities of employees.

Recommendation 6. Infrastructure Canada should assess options for better integrating the Values and Ethics framework into the day-to-day work of INFC employees.

Management Response. Management accepts this recommendation. INFC's Values and Ethics Committee includes representatives from all Branches of the department who act as Ambassadors within their respective groups and who strive to make values and ethics something that everyone everywhere across the department is responsible for. The Committee will be working on developing a new Values and Ethics Action Plan for the Department which will include initiatives that will foster, support and promote values and ethics within the department and look for ways to make values and ethics relevant every day. HR will also ensure that values and ethics remains a topic of discussion at Managers' Forum and EDMC meetings, and will continue to encourage all managers and supervisors to have ongoing dialogue and discussions with their employees on values and ethics. As well, the implementation of the new Performance Management Directive this year will require that the core competency of "demonstrating integrity and respect" is included in performance agreements for all employees. This will help to ensure that a discussion of how the employee demonstrates values and ethics in their day-to-day work is taking place is taking place between managers and employees.

6 CONCLUSION

Based on audit evidence, it was found that Infrastructure Canada's Values and Ethics framework was generally well implemented and operated effectively.

Opportunities to improve the effectiveness of the Values and Ethics framework included the following:

• Ensuring that all employees confirm that they have read and will comply with the Treasury Board and departmental codes of conduct and policies related to conflicts of interest and post-employment;
• Revising specific wording of some sections of the INFC Conflict of Interest and Post-Employment policy to ensure that it complements the Treasury Board policy instrument;
• Strengthening the processes in place to carry out the function of the Integrity Officer;
• Strengthening performance measures and formalizing the monitoring of the implementation of the Values and Ethics framework;
• Updating the information available to employees on the intranet; and
• Assessing options for better integrating the Values and Ethics framework into the day to-day work of INFC employees.

7 STATEMENT OF CONFORMANCE

The audit conforms to the International Standards for the Professional Practice of Internal Auditing and the Internal Auditing Standards for the Government of Canada as supported by the results of the quality assurance and improvement program.

8 MANAGEMENT RESPONSE AND ACTION PLAN

	Recommendation	Management Action Plan	OPI and Due Date
1	Infrastructure Canada should revise specific wording in some sections of the INFC Conflict of Interest and Post-Employment Policy to ensure that it complements Treasury Board policy instruments.	Management accepts this recommendation. HR will review the INFC Conflict of Interest and Post-Employment Policy in order to modify wording in certain sections of the policy to ensure that the wording is similar to that mentioned in the TBS policy.	Director General, Human Resources September 30, 2014
2	Infrastructure Canada should work with the Office of the Integrity Officer to enhance processes in place to carry out the function.	Management accepts this recommendation. HR will work closely with the office of the Integrity Officer to clearly define roles and responsibilities and to ensure that liaising is done between both offices on a regular basis.	Director General, Human Resources December 31, 2014
3	Infrastructure Canada should ensure that all employees confirm that they have read and will comply with the Treasury Board and departmental codes of conduct and policies related to conflicts of interest and post-employment.	Management accepts this recommendation. HR will follow up with INFC employees who have not yet confirmed that they have read and will comply with the Codes and policies and will request that employees confirm that they have fulfilled this condition of employment. HR will continue to track progress towards this goal in the tracking sheet.	Director General, Human Resources September 30, 2014
4	Infrastructure Canada should strengthen performance measures and formalize the monitoring of the implementation of the Values and Ethics framework.	Management accepts this recommendation. The Values and Ethics Committee will begin developing the new Values and Ethics Action Plan and will ensure that all initiatives included in the new Action Plan include measurable outcomes. Additionally, INFC will put more structured approaches in place to ensure that the monitoring and oversight of the Action Plan is properly documented. The Values and Ethics Officer and Champion will continue to meet on a regular basis to review and discuss the values and ethics framework and a record of these meetings and discussions will be kept on file. The Values and Ethics Action Plan will continue to be presented at INFC's People Management Committee meeting on a quarterly basis and a record of this will be kept in the PMC minutes. Also, presentations on the values and ethics framework will continue to be made to the Departmental Audit Committee as requested.	Director General, Human Resources December 31, 2014
5	Infrastructure Canada should update the information available on the intranet site to ensure that it is current, relevant and accessible.	Management accepts this recommendation and is committed to updating the values and ethics information on the Intranet. HR will review key values and ethics information currently posted on the website to ensure that the information is accurate and up-to-date and will make adjustments where necessary.	Director General, Human Resources September 30, 2014
6	Infrastructure Canada should assess options for better integrating the Values and Ethics framework into the day-to-day work of INFC employees.	Management accepts this recommendation. INFC's Values and Ethics Committee includes representatives from all Branches of the department who act as Ambassadors within their respective groups and who strive to make values and ethics something that everyone everywhere across the department is responsible for. The Committee will be working on developing a new Values and Ethics Action Plan for the department which will include initiatives that will foster, support and promote values and ethics within the Department and look for ways to make values and ethics relevant every day. HR will also ensure that values and ethics remains a topic of discussion at Managers' Forum and EDMC meetings, and will continue to encourage all managers and supervisors to have ongoing dialogue and discussions with their employees on values and ethics. As well, the implementation of the new Performance Management Directive this year will require that the core competency of "demonstrating integrity and respect" is included in performance agreements for all employees. This will help to ensure that a discussion of how the employee demonstrates values and ethics in their day-to-day work is taking place is taking place between managers and employees.	Director General, Human Resources December 31, 2014

Appendix A: Audit Criteria

• 1.1 A Code of Conduct has been introduced and integrated into the Department;
• 1.2 INFC demonstrated its commitment to explicitly integrate the Values and Ethics framework into departmental processes;
• 1.3 Information on the Values and Ethics framework was made available to, and understood by, employees;
• 1.4 Employees were held accountable for responsibilities related to the Values and Ethics framework; and,
• 1.5 INFC monitored and evaluated the progress of the initiatives within the Values and Ethics framework.