Whistle-blower Program: recommendations

A component of each whistle-blower investigation is, where possible and appropriate, to determine underlying causes of procedural failure or control weakness leading to a concern being reported.

Recommendations are raised to the attention of Administration with a view that, if implemented, these corrective actions would mitigate opportunity for similar activities to reoccur.

Recommendations are made based on the concern or issue reported and are not limited to substantiated allegations.

2024 Recommendations

2024 Q2 Recommendations

Year	Category of Reported Concern	Nature of Allegation	Conclusion and Corrective Action
Q2 2024	HR, Diversity, and Respectful Workplace	It was alleged that a City employee acted in a conflict of interest during recruitment for a vacant position.	The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated as a policy violation. Investigation determined that circumstance necessitated the employee be placed in a known conflict of interest, which was then appropriately managed to mitigate adverse effect. As a result of the investigation, the Whistle-blower Program recommended that Administration provide clarity regarding the various recruiting options available to hiring managers.
Q2 2024	Health, Safety and Environment	It was alleged that a city employee was engaging in an unsafe recreational activity in the workplace.	The Whistle-blower Program’s investigation determined the allegation to be substantiated. The investigation did not, however, determine wrongdoing. The investigation confirmed that a lawful recreational activity occurring in certain work areas was not aligned with The City’s current work safe culture. As a result of the investigation the Whistle-blower Program recommended that Administration determine how to support similar recreational activities in a manner that aligns to The City’s work safe culture.

Year

Category of Reported Concern

Nature of Allegation

Conclusion and Corrective Action

Q2 2024

HR, Diversity, and Respectful Workplace

It was alleged that a City employee acted in a conflict of interest during recruitment for a vacant position.

The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated as a policy violation.

Investigation determined that circumstance necessitated the employee be placed in a known conflict of interest, which was then appropriately managed to mitigate adverse effect.

As a result of the investigation, the Whistle-blower Program recommended that Administration provide clarity regarding the various recruiting options available to hiring managers.

Q2 2024

Health, Safety and Environment

It was alleged that a city employee was engaging in an unsafe recreational activity in the workplace.

The Whistle-blower Program’s investigation determined the allegation to be substantiated. The investigation did not, however, determine wrongdoing.

The investigation confirmed that a lawful recreational activity occurring in certain work areas was not aligned with The City’s current work safe culture.

As a result of the investigation the Whistle-blower Program recommended that Administration determine how to support similar recreational activities in a manner that aligns to The City’s work safe culture.

2023 Recommendations

2023 Q4 Recommendations

Year	Category of Reported Concern	Nature of Allegation	Conclusion and Corrective Action
Q4 2023	Business Integrity	It was alleged that an employee in a procurement decision-making capacity was in a conflict of interest.	The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated. The investigation determined that while the nature of the relationship did not require disclosure as per The City’s Conflict of Interest policy and the employee was not involved in the selection of the successful vendor, a perception of a conflict of interest remained undocumented. As a result of the investigation, the Whistle-blower Program recommended that Administration reinforce to the employee the need for transparency and fairness in the procurement process and to disclose all relationships which can be perceived as conflicting with their public duties to ensure appropriate mitigation of associated risks.
Q4 2023	Business Integrity	It was alleged that an employee in a procurement decision-making capacity was in a conflict of interest.	The Whistle-blower Program’s investigation determined the allegation to be substantiated. The investigation confirmed that in failing to disclose their conflict of interest, procurement decisions made benefited a private interest of the employee, in violation of the Code of Conduct, the Conflict of Interest Policy, and the Procurement Policy. As a result of the investigation, the Whistle-blower Program made several operational recommendations to strengthen procedures and to supplement corrective action taken by Administration to address the employee’s policy violations.

Year

Category of Reported Concern

Nature of Allegation

Conclusion and Corrective Action

Q4 2023

Business Integrity

It was alleged that an employee in a procurement decision-making capacity was in a conflict of interest.

The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated.

The investigation determined that while the nature of the relationship did not require disclosure as per The City’s Conflict of Interest policy and the employee was not involved in the selection of the successful vendor, a perception of a conflict of interest remained undocumented.

As a result of the investigation, the Whistle-blower Program recommended that Administration reinforce to the employee the need for transparency and fairness in the procurement process and to disclose all relationships which can be perceived as conflicting with their public duties to ensure appropriate mitigation of associated risks.

Q4 2023

Business Integrity

It was alleged that an employee in a procurement decision-making capacity was in a conflict of interest.

The Whistle-blower Program’s investigation determined the allegation to be substantiated.

The investigation confirmed that in failing to disclose their conflict of interest, procurement decisions made benefited a private interest of the employee, in violation of the Code of Conduct, the Conflict of Interest Policy, and the Procurement Policy.

As a result of the investigation, the Whistle-blower Program made several operational recommendations to strengthen procedures and to supplement corrective action taken by Administration to address the employee’s policy violations.

2023 Q2 Recommendations

Year	Category of Reported Concern	Nature of Allegation	Conclusion and Corrective Action
Q2 2023	HR, Diversity, and Respectful Workplace	It was alleged that two City employees make a hand gesture known to be offensive	The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated as wrongdoing.The investigation determined that the hand gesture is not always offensive and the context in which it was made was not in violation of the Respectful Workplace Policy.As a result of the investigation, the Whistle-blower Program made a recommendation for Administration to consider how to incorporate potentially offensive hand gestures into its diversity-related training.
Q2 2023	Misuse, Misappropriation of Assets	It was alleged that a City employee was misusing a City vehicle.	The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated. The investigation determined the use of the vehicle did not violate City policy. As a result of the investigation, the Whistle-blower Program recommended that Administration review the alignment of the employee’s use of a City vehicle with their current role and responsibilities.
Q2 2023	Business Integrity	It was alleged that an employee used personal information of a colleague inappropriately.	The Whistle-blower Program’s investigation determined the allegation to be substantiated. The investigation confirmed that the employee used an individual’s personal information lawfully collected by The City, for a reason other than the reason it was collected, in violation of the Code of Conduct and contravention of the FOIP Act. As a result of the investigation, the WBP recommended that Administration take appropriate corrective action including refreshing the employee’s privacy training to reinforce their obligations to remain compliant with policy.

2023 Q1 Recommendations

Year	Category of Reported Concern	Nature of Allegation	Conclusion and Corrective Action
Q1 2023	HR, Diversity, and Respectful Workplace	It was alleged that a City employee engaged a City colleague in an aggressive manner.	The Whistle-blower Program’s investigation determined the allegation to be substantiated. Investigation determined that the employee’s behaviour violated the City’s Code of Conduct, Workplace Violence Prevention Policy, Respectful Workplace Policy, and Labour Relations Policy. As result of the investigation, Administration has committed to ensuring that appropriate corrective action occurs, including reinforcement of expectations regarding appropriate workplace behaviour and reporting protocols.
Q1 2023	HR, Diversity, and Respectful Workplace	It was alleged that promotions and salary increases provided to specific City staff were not compliant with the Staffing Principles and Guidelines in effect during the City’s Organizational Realignment period.	The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated. Investigation determined that changes in staff positions and salaries occurred in alignment with the Employment Policy and the Exempt Staff Policy, and that the Staffing Principles and Guidelines were not applicable. The Whistle-blower Program recommended that job descriptions for the relevant positions be appropriately updated to reflect new responsibilities.
Q1 2023	HR, Diversity, and Respectful Workplace	It was alleged that a City employee, acting in the capacity of hiring manager, was in a conflict of interest.	The Whistle-blower Program’s investigation determined the allegation to be substantiated. The investigation confirmed that an existing relationship with the successful candidate was insufficiently disclosed during the recruitment process, to support the development of an effective mitigation strategy and align with the Employment Policy or the Conflict of Interest Policy. As a result of the investigation, appropriate corrective action was taken by Administration.
Q1 2023	Misuse, Misappropriation of Assets	It was alleged that an inappropriate overtime claim by a City employee resulted in an inappropriate payment by The City.	The Whistle-blower Program’s investigation determined the allegation to be unsubstantiated. Investigation determined the overtime claim and approval for payment did not violate policy. As a result of the investigation, the WBP made recommendations for Administration to clarify policy language regarding overtime eligibility and to strengthen employment letters.
Q1 2023	Misuse, Misappropriation of Assets	It was alleged that a group of City employees inappropriately expensed an out‐of‐town meeting.	The Whistle‐blower Program’s investigation determined the allegation to be unsubstantiated as wrongdoing. The investigation determined that the meeting related to an appropriately approved and funded learning and team building event. While expenses incurred were found to be aligned with City policies, the investigation revealed instances of non‐compliance with expense approval procedures. The Whistle‐blower Program has recommended reinforcement of approval procedures be directed toward credit card holders in this work area to ensure ongoing compliance with City policy.
Q1 2023	Health, Safety, and Environment	It was alleged that some City employees were not provided with required personal protection equipment (PPE), necessitating personal purchases.	The Whistle‐blower Program’s investigation determined the allegation to be unsubstantiated as wrongdoing. The investigation determined that Occupational Health & Safety compliant PPE is provided to all employees in this work area. Some employees were found to be dissatisfied with the PPE provided and were informed that no alternatives would be provided, but that they could purchase their own additional PPE. The Whistle‐blower Program recommended an assessment be conducted of the suitability of PPE issued to this team and to evaluate the need for any PPE to be acquired personally, and to ensure any such PPE is safety compliant
Q1 2023	Misuse, Misappropriation of Assets	It was alleged that a City employee was abusing remote work opportunities.	The Whistle-blower Program’s investigation determined the allegation to be substantiated. Investigation determined the employee was working remotely from their personal business premises and engaging in activities determined to be violations of the Labour Relations Policy and the Conflict of Interest Policy. The Whistle-blower Program recommended that Administration take corrective action to address the policy violations and reinforce policy expectations with the employee.