Financial Transactions and Reports Analysis Centre of Canada

Part I. Values and ethics training plans

Question 1

Has your organization developed department-specific values and ethics training plans down to the divisional level?

• Yes

If not, to what level have department-specific values and ethics training plans been developed and what is your target time frame for completing this work?

N/A

Question 2

Has your organization fully implemented department-specific training plans?

• No

If not, what is your target time frame for completing this work?

The Financial Transactions and Reports Analysis Centre (the Centre or FINTRAC) has developed a new learning path for values and ethics. The mandatory learning element will be implemented in 2024-2025 and will require all current and future employees and students to complete the Canada School of Public Service training for employees once every three (3) years. Those with supervisory functions will also be required to complete the manager’s course on values and ethics.

The values and ethics learning plan will be subject to review and adjustment as required, based on any emerging trends identified through our engagement sessions and/or if the Centre becomes aware of other new and relevant learning and development opportunities or job aids.

Part II. Codes of conduct

Question 3

Has your organization reviewed its code of conduct?

• Yes, my organization has reviewed its code of conduct.

Question 4

If your organization is in the process of reviewing its code of conduct, what is your target time frame for completing the review?

In 2022, FINTRAC conducted a comprehensive review and subsequent update of its Code of Conduct, Values and Ethics (Code). Since that time, the organization has remained committed to proactively identifying areas for improvement in response to emerging trends, as well as addressing any arising queries or concerns necessitating additional clarity within the Code. To date, work is already underway to bolster the Code in the areas of social media usage and the duty of loyalty, the safeguarding of information and the need for discretion, and the disclosure of travel and hospitality offers by third parties to employees that would be on official FINTRAC business, and where an assessment is required to examine whether acceptance could give rise to a real, perceived or potential conflict.

The sensitive nature of our mandate requires a high level of professionalism, as well as behaviour that upholds the highest ethical standards in order to maintain public trust. It is critical that all employees of FINTRAC have a heightened sensitivity and awareness of the importance of protecting our information, but are also transparent, and maintain our credibility and trust by conducting themselves in ways that bears the public scrutiny and upholds our integrity and trust with our law enforcement partners and the many reporting entities that we regulate.

In addition to the Centre’s internal evaluations and updates, the organization sought the expertise of Gartner, a reputable human resources consulting firm, to conduct a thorough assessment of the Code. Gartner's comprehensive review concluded that there are no significant gaps in the Code. Furthermore, Gartner provided valuable recommendations for potential enhancements and refinements, which will be carefully considered in the forthcoming updates to the Code.

Question 5

If your organization has completed the review of its code of conduct, did this review lead to updates?

• Yes, my organization updated its code of conduct.

Please briefly describe the nature of any updates made (e.g., to clarify expected behaviours, to align with the emerging context, to include emerging risks) or explain why no updates were deemed necessary.

FINTRAC's Code establishes the framework for employee behavior and representation, both professionally and personally. It guides employees on maintaining impartiality in the public sector and outlines procedures for reporting serious wrongdoing.

In the latest 2022 updates, the Centre incorporated an employee-developed values statement into its Code. This statement complements the public sector values and highlights the significant contributions of our staff in defining the expected behaviors for all employees. Now, central to our Code and our culture, this values statement guides our employees in their conduct and decision-making. 

Additionally, the updated Code clarifies procedures for employees to report allegations of serious wrongdoing in the workplace. It outlines a straightforward process for disclosing concerns to the designated Senior Officer, ensuring transparency and accountability. Furthermore, the Ombuds has been informed of these procedures so that they can provide appropriate guidance and support to employees.

Another significant change that resulted from the review was a re-alignment of the conflict of interest process. Prospective employees now complete their confidential report to disclose any real, apparent or potential conflict of interest risks prior to receiving a letter of offer. In doing so, the prospective employee can be made aware of any conditions or mitigation measures that would be required, so that they can make an informed decision on whether or not to accept the offer of employment.

Given that employees are accountable for disclosing any real, apparent or potential conflict of interests, the definitions of what needs to be disclosed were enhanced to draw greater emphasis to declaring assets, outside activities, or relationships that involve reporting entities. This added clarity has resulted in an increase in reporting and consultations by employees and prospective employees and is reducing the overall risks to the Centre in areas that could pose vulnerabilities if they were not otherwise disclosed and/or mitigated.

Furthermore, requiring employees to declare any close personal or family relationships with other employees at the Centre and/or reporting entities also brings greater transparency and better positions management to work with the employee to mitigate any potential conflict of interest risks in this area as well.

Part III. Discussions on personal accountability in upholding public service values and ethics

Question 6

What activities or actions has your organization undertaken to foster a conversation at all levels on personal accountability to uphold our public service values and ethics?

• Dedicated discussions at executive and management committee meetings
• All-staff engagements (e.g., town halls)
• Focused engagement sessions for specific functional areas (e.g., operations, finance, communications, policy, human resources)
• Focused engagement sessions on specific topics (e.g., conflicts of interest, social media, emerging technologies)
• Engagement sessions with equity groups, employee groups, networks and communities
• Inclusion in employees’ performance and talent management cycle discussions
• Specific values and ethics communications campaigns

Please provide additional details on activities that you have undertaken, including those not listed above.

Values and ethics has remained a central topic of discussion within our Management Advisory Committee (MAC) and the Executive Committee (EXCO). Examples include discussions on the implementation of the Government of Canada’s hybrid model from a values and ethics perspective, discussions related to conflict of interest matters and discussions on the revisions to FINTRAC’s Code of Conduct, Value and Ethics and the Centre’s Value Statement. The Champion of Values and Ethics also recently presented their strategic vision for their engagement and outreach activities to MAC and EXCO. The Champion of Values and Ethics is also a member of MAC. In June, FINTRAC will host its annual all-staff Town Hall, during which our Chief Executive Officer will address our ongoing commitment to values and ethics.

Since the release of the Deputy Ministers’ Task Team on Values and Ethics Report, our engagement activities have begun with our leadership cadre. A mandatory ethical leadership course was delivered to initiate dialogue on the matter. The Centre also regularly holds a Manager’s Forum to have open, honest and frank conversations with the leadership cadre. In May, the Chief Executive Officer and the Chief Human Resources Officer held a session to discuss values and ethics and the responsibilities of our leadership. The hybrid model is another topic that was also previously discussed. As our capacity to monitor compliance increased and it became evident that compliancy was inconsistent across the Centre, discussions were held on accountability and integrity. The impact of these discussions and deliberate actions taken by our leadership resulted in compliancy levels increasing to above 90% across the Centre.

To expand the dialogue to all employees, engagement sessions are being planned for the fall. Currently, customized scenarios are being developed for each public sector value that will drive the conversation. To facilitate interactive and meaningful discussions, these sessions will be organized by functional area in small groups. This approach is designed to encourage active participation and ensure that all voices are heard. We believe that these focused discussions will not only deepen employees' understanding of our core values but also foster a sense of ownership and commitment to upholding them in their respective roles.

To ensure diverse perspectives, consultation with the Employment Equity, Diversity, and Inclusion working group is also underway in the development of these scenarios. The ongoing collaboration with the working group aims to leverage diverse insights.

To foster accountability and promote growth, corporate commitments specific to values and ethics have been included in all performance agreements for 2024-2025. Values and ethics are also discussed through talent management discussions with our leadership cadre. As part of the program, employees are identified for various leadership programs to help them to maximize their potential. Many of these programs incorporate ethical leadership components.

Finally, with respect to communication campaigns, our Values and Ethics Champion is an integral stakeholder for engaging with staff. The Champion will continue to be leveraged to issue communiqués on important values and ethics related matters. 

Question 7

Has your organization taken any actions to ensure that conversations on personal accountability to uphold our public service values and ethics occur on a continuing basis?

• Included as part of the onboarding process for new employees
• Incorporated in employees’ professional development and mandatory learning plans
• Integrated in career succession planning (e.g., supervisor, manager, director)

Please provide details on activities that you have undertaken, including those not listed above.

As part of FINTRAC’s new learning path, both new and existing employees will be required to complete mandatory training from the Canada School of Public Service on values and ethics. This will be incorporated in the onboarding process for new employees and integrated in our Human Capital Management System, Workday, to roll out to all employees and managers. There will also be a requirement to renew the training every three (3) years.

Within the learning path, other learning and development resources such as job aids, podcasts, and related courses will be listed and updated on an ongoing basis. Employees and managers will be encouraged to incorporate these in their individual learning plans, if there are areas that they wish to strengthen and that would be beneficial to their role and position within the organization.

In order to increase personal accountability, all employees and managers will be required to complete an annual acknowledgement through their performance agreement that they have read, understood and will comply with FINTRAC’s Code of Conduct, Values & Ethics, and that they also understand that they must submit a new Confidential Report whenever there is a change to their personal affairs or official duties that could give rise to a conflict of interest.

The corporate performance commitments have also been strengthened, and employees and supervisors will be assessed both on the key leadership competency, but also on what actions they have taken to advance the Government of Canada’s priority to engage in conversations and promote values and ethics within the workplace.

FINTRAC has a talent management program for its leadership cadre, which includes discussions on succession planning. Through this program, employees showing potential for growth and advancement are identified for leadership programs aimed at maximizing their potential. Many of these programs include components focused on ethical leadership.

Additionally, employees undergo character leadership assessments and receive 360-degree feedback to pinpoint areas for further growth. This information guides the selection of appropriate mentorship and training opportunities, which are then incorporated into individual learning plans.

Part IV. Additional information

Question 8

What recurring themes (e.g., social media, emerging technology, conflicts of interest) have emerged from conversations with employees (e.g., students, new public servants, front-line service providers, managers, executives, members of functional/horizontal communities/employee networks) across your organization?

Through our interactions with employees spanning various roles within the organization, several recurring themes have surfaced. Firstly, there are notable concerns surrounding social media usage, particularly regarding the impact of personal postings on platforms like Reddit, where anonymity can blur professional boundaries and potentially compromise our organizational integrity. Secondly, outside employment and volunteer activities have been a focal point of discussion, highlighting the necessity for clear guidelines to manage conflicts of interest and maintain transparency and impartiality.

Additionally, there have been ongoing dialogues regarding the utilization of generative artificial intelligence (AI) in the development of the Centre’s Policy on use of Generative Artificial Intelligence (GenAI). As this technology evolves rapidly, it is essential to establish robust protocols that align with our organizational values and legal obligations.

While the majority of our leaders fulfill their duties as instructed, a new emerging theme related to the need for some of our leaders to be decisive and to carry out, to the very best of their ability, the lawful decisions of our senior management and Ministers of the Crown, who are accountable to Parliament and Canadians even when there is not always agreement with the direction. Our leaders are expected to remain resolute in advancing progress and to maintain focus amidst the various priorities and pressures prevalent in today's professional environment.

Overall, these recurring themes underscore the dynamic landscape within which our organization operates, highlighting the need for proactive engagement and strategic policymaking to navigate emerging challenges and opportunities effectively.

The Centre looks forward to further dialogue with employees on these topics and others during the upcoming all staff engagement sessions planned for this fall.

Question 9

How have you adjusted your learning activities to address recurring themes (e.g., adjusted training plans, developed specific case studies, invited expert speakers to focus on emerging themes)?

In response to the recurring themes, the Centre is taking a multifaceted approach to adapt our learning activities and foster a culture of continuous improvement within the organization. Firstly, we have prioritized the delivery of ethical leadership training to our leadership cadre, to initiate dialogue and begin equipping them with the necessary tools and frameworks to effectively navigate complex ethical dilemmas and promote a culture of integrity and accountability across all levels.

Furthermore, we have undertaken revisions to our Code of Conduct, ensuring alignment with evolving industry standards and best practices, while also addressing emerging concerns raised by employees. These updates serve to provide clearer guidance and reinforce our organizational commitment to upholding the highest ethical standards.

Looking ahead, our engagement sessions scheduled for the fall will feature tailored scenarios and facilitate a collaborative exploration of real ethical challenges and foster a deeper understanding of our organizational values. These sessions will serve as a platform for facilitated and engaging discussions on values and ethics, encouraging active participation and knowledge sharing among participants.

Moreover, we have proactively sought to broaden our organizational perspective by inviting speakers to address areas that are pertinent to our workforce and our values. Recent speaker engagements have covered topics such as workplace inclusion, neurodiversity, and the nuances of addressing micro aggressions in the workplace. These sessions aim to promote awareness, understanding, and dialogue around important issues that impact our organizational culture and dynamics.

Overall, our concerted efforts to adjust learning activities reflect our commitment to continuous improvement and ensuring that our workforce remains equipped with the necessary knowledge and skills to navigate evolving ethical challenges effectively. By fostering a culture of learning, collaboration, and ethical leadership, we aim to uphold the values and integrity that are foundational to our organization's mission and mandate. Our learning path will continue to be adjusted as necessary to address emerging trends and seize new learning opportunities of relevance.

Question 10

Are there any actions or learning activities that have been particularly successful in fostering conversations within your organization (e.g., new tools, creative approaches that have resonated well with employees and managers, meeting with small groups, equipping managers to lead conversations, equipping values and ethics office/practitioners)?

One notable initiative that has proven successful in fostering meaningful conversations within our organization related to conflict of interest is the customization of our confidential report form. Previously, FINTRAC utilized a generic form that is used across the federal public service. However, recognizing the need for greater specificity and clarity, we tailored this form to better suit our organizational context, particularly regarding disclosures related to potential conflicts of interest.

By refining the definitions within the report form to highlight the types of disclosures employees should make in situations where there is a heightened risk to the Centre for a real, potential, or perceived conflict of interest, we have seen a notable increase in employee engagement. This tailored approach has prompted more questions from employees and enhanced their understanding of their disclosure responsibilities. Employees now have a clearer understanding of what they should disclose, as the onus is placed on them to report potential conflicts.

Moreover, implementing this customized report form as part of our pre-employment process has initiated proactive conversations to mitigate or eliminate any identified risks. Candidates are provided with transparent information about our conflict of interest policies, minimizing surprises and ensuring alignment with our organizational values. Consequently, this proactive approach has contributed to keeping conflict of interest risk levels low within the Centre.

Overall, the customization of our report form has not only facilitated more informed and transparent communication but has also played a crucial role in nurturing a culture of integrity and accountability within our organization. The Centre continues to review and enhance the form to bring more rigour and foster meaningful conversations in areas of higher risk to the organization.

In addition, the Centre is looking forward to engaging more fully with employees on all of our core values in the upcoming fall engagement sessions. These sessions will provide an opportunity for employees and management to delve into the intricacies of our organizational values and how they manifest in their day-to-day work.

To facilitate interactive and meaningful discussions, these sessions will be organized by functional area in groups of 25 or less and both official languages. This approach is designed to encourage active participation and ensure that all voices are heard. We believe that these focused discussions will not only deepen employees' understanding of our core values but also foster a sense of ownership and commitment to upholding them in their respective roles.

By proactively engaging employees in conversations about our core values, we aim to strengthen our organizational culture and further reinforce our collective dedication to integrity, transparency, and accountability. We look forward to the insights and perspectives that will emerge from these sessions as we continue to cultivate a workplace environment grounded in shared values and mutual respect.

Question 11

What indicators will be used to measure increased employee awareness of the role of values and ethics in their daily work (e.g., Public Service Employee Survey, pulse surveys, engagement with focus groups)?

FINTRAC will employ a number of formal and informal means to measure the effectiveness of our efforts to increase awareness of the role of values and ethics at the Centre.

As with all past Public Service Employee Surveys, FINTRAC has established a working group tasked with analyzing the results and devising an enterprise wide action plan on how to address the concerns that have been raised through the survey. In addition, individual sectors within the Centre develop their own sector specific plans to improve working conditions and help ensure that the Centre is fostering a safe, inclusive and ethical workforce. With the next survey occurring this fall, the Centre will be able to evaluate the effectiveness of its various initiatives underway and will again leverage the results and conduct an analysis with a values and ethics lens, including ethical leadership, to determine if there are any areas requiring further attention.

Conversations are also occurring with the launch of the 2024-2025 performance review period to set the expectations with respect to values and ethics. All employees and supervisors will have specific corporate commitments related to values and ethics, and at the end of the year, the results will contribute to the overall assessment and the final performance rating.

Additionally, ongoing dialogues with our Ombuds will serve as another avenue for assessing our effectiveness. The Ombuds will share trends and highlight areas of concern, offering valuable insights into potential areas for improvement.

Lastly, exit surveys are administered to all departing employees, and efforts are underway to ensure that these surveys capture data relevant to values and ethics. This approach enables the organization to identify emerging trends and address any concerns promptly and effectively.

Question 12

Will these indicators be disaggregated by identity factors?

• Yes

Question 13

Is there any additional information that you would like to share regarding your organization’s work on values and ethics (e.g., to advance particular recommendations of the Deputy Ministers’ Task Team on Values and Ethics Report)?

The importance of values and ethics has always been a key focus at FINTRAC. Since 2019, our agency has been deeply engaged in fostering a culture steeped in values and ethics. Spearheaded by our previous Director and Chief Executive Officer and following extensive consultations with employees, FINTRAC collectively crafted its first values statement in 2020. This statement now serves as the cornerstone of our Code of Conduct, guiding principles, and ethical framework. Furthermore, it is prominently displayed on our external website, underscoring our commitment to integrity and respect.

Building upon this foundation, our Champion of Values and Ethics undertook a series of messaging campaigns throughout 2021-2022. These initiatives were designed to unpack and socialize each of our core values within the organization. By fostering open dialogue and understanding, we aim to embed these values into the fabric of our organizational culture, guiding our actions and decisions at every level.

This year, the Centre is also introducing a new Values and Ethics award as part of our Awards and Recognition Program. This award will recognize individuals who consistently exemplify our organizational values in their daily work, demonstrating unwavering dedication, integrity, and a strong work ethic.

FINTRAC remains committed and engaged and we are eager to continue the important dialogue on values and ethics within our organization.