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Audit values and ethics W2008

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29 pages
AUDIT OF VALUES AND ETHICS CONTROL FRAMEWORK FINAL REPORT Prepared by: Office of Internal Audit and Evaluation NOVEMBER 2008 Report tabled to the Parks Canada Audit Committee meeting on December 9, 2008 Parks Canada Agency Audit of values and ethics control framework __________________________________________________________________________________________ Her Majesty the Queen in right of Canada, as represented by the Chief Executive Officer of Parks Canada, 2008 Catalogue No. : R64-353/2009E-PDF ISBN : 978-1-100-11793-5 2OIAE November 2008 Parks Canada Agency Audit of values and ethics control framework __________________________________________________________________________________________ TABLE OF CONTENTS SUMMARY ...........................................................................................................................4 I INTRODUCTION .........................................................................................................................8 II OBJECTIVES AND SCOPE.........................................................................................................9 2.1 Objectives..................................................................................................................... 9 2.2 Scope ..................................................... ...
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AUDIT OF VALUES AND ETHICS CONTROL FRAMEWORK
FINAL REPORT
Prepared by:  Office of Internal Audit and Evaluation  NOVEMBER 2008
Report tabled to the Parks Canada Audit Committee meeting on December 9, 2008     
 
 
Parks Canada Agency Audit of values and ethics control framework __________________________________________________________________________________________                                    Her Majesty the Queen in right of Canada, as represented by the Chief Executive Officer of Parks Canada, 2008 Catalogue No. : R64-353/2009E-PDF ISBN : 978-1-100-11793-5  
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Parks Canada Agency Audit of values and ethics control framework __________________________________________________________________________________________     TABLE OF CONTENTS  SUMMARY...........................................................................................................................4 I DURONTINIOCT......................................................................................................................... 8 II OBJECTIVES AND SCOPE......................................................................................................... 9 2.1 Objectives..................................................................................................................... 9 2.2 Scope............................................................................................................................ 9 III APPROACH AND METHODOLOGY......................................................................................... 9 IV  STATEMENT OF ASSURANCE.................................................................................................. 10 V OVERALL CONCLUSION........................................................................................................... 11 VI OBSERVATIONS AND RECOMMENDATIONS..................................................................... 11 6.1 The Agency has defined its values and communicated them..................................... 11 6.2 Management shows by its actions that it will not allow any breach to the Agency’s integrity or ethics.................................................................................................................. 17 6.3 There are official channels of communication permitting employees to report behaviours deemed inappropriate........................................................................................ 27
 Report approved by Parks Canada CEO on December 9, 2008      
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Parks Canada Agency    SUMMARY  The November 2007 Treasury Board Secretariat Guide for departmental audit committees, stipulates: “The Audit Committee shall review, at least annually, the arrangements established by management to exemplify and promote public service values and to ensure compliance with laws, regulations, policies, and standards of ethical conduct.” To assist the audit committee in fulfilling this requirement, an audit of values and ethics policies and procedures in place has been included with the 2008-2009 internal audit and assessment plan approved in May 2008.  The purpose of this audit is to confirm that the procedures and policies for promoting the Agency’s values and ethics are part of the management control framework.  The audit team consulted the ombudsman’s office’s website; surveyed and conducted interviews with stakeholders in various sectors; studied various documents pertaining to values and ethics, such as:  - Parks Canada Agency Code of ethics; - The Ombudsman’s Office’s first report; - Policy: Towards a harassment-free workplace; - The Public Servants Disclosure Protection Act and Policy;  Conflict of Interest Act; -- Guidelines and informal conflict management policy; - Terms of reference – Office of the Ombudsman; - Other related documents  Audit results are classified into categories in accordance with the Parks Canada Agency rating system and are presented below.  Ref. Criteria   6.1.1 Management has defined the Agency’s values  The Agency ensures that the employees know 6.1.2 the values to which the Agency adheres  Employees receive regular formal reminders 6.1.3 that they must confirm their understanding of and compliance with the Code of ethics
 Management has developed various  mechanisms for regularly reminding all 6.2.1 employees of the importance of integrity and  ethics in communications sent  
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 Audit of values and ethics control framework                                                                                                     
Parks Canada Agency      Infractions of policies, procedures and the 6.2.2 iCnovdeset iogf aettehdi cs are documented and quickly 
 Wrongdoings as well as the measures taken to 6.2.3 remedy them are communicated to the public
6.3.1 There is an independent monitoring mechanism for settling ethics and values problems 6.3.2 Anonymity is ensured in case of disclosure
 Statement of Assurance  The audit was conducted in compliance with the standards of theAgency’s internal audit policy. According to these standards, the audit must be planned and conducted in such a way as to enable the audit team to attest to the quality of the audit findings.  The audit team’s findings are based on the evaluation of observations made pertaining to the objectives and criteria described and reported in the audit conducted from July to October 2008.  In our opinion, sufficient audit work has been performed and the necessary evidence has been gathered to support the conclusions contained in this report.  Overall Conclusion  The federal public sector must be a leader in promoting values and ethical behaviour not only to show the public that it is responsible for its actions but also to attract the interest of individuals as an employer. Some initiatives carried out by the Agency’s management, such as establishing values; the introduction of its Code of ethics; appointment of a senior values and ethics officer, implementation of policies that are specific to the Agency, etc. are good program components for ensuring the promotion and application of its values. However, there is a lack of consistency between the roles and responsibilities of the sectors involved. The components in place are disparate and not related to a specific program. To improve the program’s chances for success, other measures (e.g. showcasing the Agency’s values, communication of the policy on disclosure of information concerning wrongdoing or offences in the workplace) need to be developed to strengthen and complete the values and ethics program.     OIAE
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Parks Canada Agency      Recommendations  The Senior Values and Ethics Officer must:  1. In collaboration with the human resources directorate, ensure that the harassment policy reflects his office’s role; 2. In collaboration with the human resources directorate, clarify the relationship between the two sets of values existing in the Agency (those included in the Code of ethics and the human resources values and operating principles); 3. In collaboration with the human resources directorate, ensure that the retention process for documents related to values and the Code of ethics is standard throughout the Agency; 4. Obtain clarification from the Chief executive officer on the responsibilities of the position of values and ethics officer and those of other parties involved with values and ethics;  5. In collaboration with human resources directorate, ensure that the Agency’s values-based ethics program is completed by developing accountability and follow-up tools for personnel; 6. In collaboration with the human resources directorate, define respective roles and responsibilities with regard to communicating values and ethics for the Agency’s personnel; 7. Ensure that the Agency’s personnel are aware of best practices for minimizing conflicts of interest; 8. Ensure that the Agency’s values are showcased; 9. In collaboration with the human resources directorate, ensure that the written procedure for managing conflicts of interest is applied or properly modified so that practices reflect the directives; 10. Ensure that all useful information related to disclosure of wrongdoing is communicated to employees; 11. Ensure that guidelines have been established for employees wishing to make a disclosure; 12. Ensure that the report submitted annually to the Canada Public Service Agency (CPSA) includes the information related to disclosures received for the entire Agency; OIAE6November 2008
 
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Parks Canada Agency     13. Ensure consistency between information provided in the Code of ethics and laws in effect;  14. Establish a detailed process of the steps to be followed for managers when receiving a disclosure;
15. Create a link on the Agency’s website for the regular publication of information on cases of wrongdoing and the measures taken to remedy them;  16. Ensure that a uniform process is established for transferring information in order to obtain all necessary details concerning cases of disclosures received by the entire Agency.  
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Parks Canada Agency     I INTRODUCTION  The November 2007 Treasury Board Secretariat Guide for departmental audit committees, stipulates: “The Audit Committee shall review, at least annually, the arrangements established by management to exemplify and promote public service values and to ensure compliance with laws, regulations, policies, and standards of ethical conduct.” To assist the audit committee in fulfilling this requirement, an audit of values and ethics policies and procedures in place was included with the 2008-2009 internal audit and assessment plan approved in May 2008.  Values are principles that guide behaviour. How these values are applied in daily operations determine if individuals have or not an ethical conduct. Establishing values and promoting appropriate ethics are basic components of a sound management control framework of every organization. In fact, good values anchored within an organization will foster “ethical conduct” among its employees. However, values and ethics will be devoid of meaning if they are not perceived as being rooted in the management style. Promoting these aspects must therefore be consistent and systematic if we want the Agency’s managers and employees to make them part of their daily operations.  The importance granted to values and ethics within the organization comes not only from growing concerns on the part of the public but also from changes in progress at the Agency. Among these changes, we note: the arrival in the public service of new employees with diverse backgrounds who are replacing retiring personnel; frequent transfers of employees between government departments and agencies; more partnerships with the private sector and other levels of government; operations that are often similar but different, due to the realities of each field unit; etc.  Here are some examples of conflicts that can arise from inappropriate behaviours when the values and ethics are not management elements put forward within an organisation. The risks associated with these potential conflicts are also identified.   
-Harassment in general (psychological, physical, sexual) Frequent absences, complaints, legal proceedings that  can affect the Agency’s reputation, reduced -Workplace health and safety problem productivity, increased cost for replacing personnel. -Possession of financial interests outside the Agency that May affect the employee’s performance, impartiality can cause conflict with regard to their duties in decision-making and objectivity of the employee. -Outside employment or activity which: 1) places the Runs the risk of damaging the Agency’s image or employee in a position of “appearing to represent” the reputation. Agency; 2) suggests that the Agency is incapable of performing its functions.
-Falsification of Agency’s books, accounts or records The reliability of financial data is often perceived by   the public as a confirmation of the reputation of - Dubious payments integrity of government services. Irregularities, errors ma affect the A enc ’s financial statements. OIAE 8 November 2008  
Parks Canada Agency    
 Potential repercussions on profitability. Disclosure of the Agency’s confidential information Runs the risk of adversely affecting the Agency’s operations and reputation. Breaks trust. Acceptance of gifts, privileges or benefits in business Runs the risk of harming the reputation of integrity, relations honesty. Adversely affects good faith and the sense of equity of the employees involved. Incorrect or inappropriate use of Agency property Increased costs. May infringe upon the Agency’s reputation.  To improve the values and ethics program chances for success, initiatives related to values and ethics must be developed, applied and monitored using the best possible practices. In order to make these tasks easier, the Agency introduced its own Code of ethics in 2006 and the same year, created the Ombudsman position. The Ombudsman plays a triple role within the Agency, including that of Senior Values and Ethics Officer, which consists of supporting and encouraging organizational dialogue on values and ethics.   II OBJECTIVES AND SCOPE  2.1 Objectives  The purpose of this audit is to confirm that the Agency’s procedures and policies for promoting values and ethics are part of the management control framework.  Specifically, the audit aims to substantiate that the Agency has defined its values, communicated them, and acts in accordance with them.   2.2 Scope  The audit is limited to confirming the existence of policies and procedures promoting the Agency’s values and ethics. The effectiveness of these procedures and policies was not evaluated.  In order to prevent any confusion, this audit deals with the values set out in the Agency’s Code of ethics applying to all employees of Parks Canada and not the Human Resources Values and Operating Principles.  III APPROACH AND METHODOLOGY  The audit team consulted the Ombudsman website; surveyed and conducted interviews with stakeholders in various sectors; studied various documents pertaining to values and ethics, such as:   OIAE 9 November 2008  
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Parks Canada Agency    
 - Parks Canada Agency Code of ethics; - The Ombudsman’s Office’s first report;  Policy: Towards harassment-free workplace; -- The Public Servants Disclosure Protection Act and Policy; - Conflict of Interest Act; - Guidelines and informal conflict management policy;  - Terms of reference – Office of the Ombudsman; - Other related documents.  Our observations and recommendations have been made in accordance with the Audit Reporting Rating System described below:  Audit Reporting Rating System Unsatisfactory Controls are not functioning or are nonexistent. Immediate management actions need to be taken to correct the situation. Significant Controls in place are weak. Several major issues were noted that improvements could jeopardize the accomplishment of program/operational needed objectives. Immediate management actions need to be taken to  address the control deficiencies noted. iMmodeorvate ts Some controls are in place and functioning. However, major neepdred emenissues were noted and need to be addressed. These issues could impact on the achievement of program/operational objectives. Minor Many of the controls are fun tioning as intended. However, improvements some minor changes are nececssary to make the control needed environment more effective and efficient. Controlled Controls are functioning as intended and no additional actions are necessary at this time.
  IV STATEMENT OF ASSURANCE  The audit was conducted in compliance with the standards of theAgency’s internal audit policy. According to these standards, the audit must be planned and conducted in such a way as to enable the audit team to attest to the quality of the audit findings.  The audit team’s findings are based on the evaluation of observations made pertaining to the objectives and criteria described and reported in the audit conducted from July to October 2008.  In our opinion, sufficient audit work has been performed and the necessary evidence has been gathered to support the conclusions contained in this report.   OIAE 10 November 2008  
Parks Canada Agency     V OVERALL CONCLUSION  The federal public sector must be a leader in promoting values and ethical behaviour not only to show the public that it is responsible for its actions but also to attract the interest of individuals as an employer. Some initiatives carried out by the Agency’s management, such as establishing values; the introduction of its Code of ethics; appointment of a senior values and ethics officer, implementation of policies that are specific to the Agency, etc. are good program components for ensuring the promotion and application of its values. However, there is a lack of consistency between the roles and responsibilities of the sectors involved. The components in place are disparate and not related to a specific program. To improve the program’s chances for success, other measures (e.g.: showcasing the Agency’s values, communication of the policy on disclosure of information concerning wrongdoing of offences in the workplace) need to be developed to strengthen and complete the values and ethics program.    VI OBSERVATIONS AND RECOMMENDATIONS  6.1 The Agency has defined its values and communicated them  6.1.1 Criteria Management has defined the Agency’s values.  Minor riemqpuriorvese ments cMhaannyg eosf  atrhee  nceocnetsrsoalsr ya rteo  fmuankctei othnie ncgo anst rionlt eenndvierdo. nHmoewnte vmeor,r es oefmfee ctmiivneo ar nd efficient.   Observations  The Agency has established the values it wishes to see implemented by all employees in carrying out their daily tasks, regardless of their area of expertise, and grouped them into four categories. These are the democratic, the professional, the ethical and the values related to people. These values have been defined in a Code of ethics in order to formalize the behaviours deemed appropriate and to create a framework for the management of operations such that the Agency’s integrity cannot be doubted.  Furthermore, despite its status as a distinct employer, the Agency and its employees are not exempt from compliance with the various laws, policies and administrative programs related to Parks Canada values.  Here are a few examples of laws and policies related to values the Agency adheres to:  Democratic values: - Access to Information Act; - Management Accountability Framework; OIAE 11 November 2008  
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