On September 1, 2018, Council for the Town of Halton Hills appointed Principles Integrity to act as its Integrity Commissioner to provide accountability services to the Town. The role of the Integrity Commissioner is to support the Town’s ethical framework by providing advice and education on the Code of Conduct, and on related Town policies, procedures, protocols and rules relating to the ethical conduct of Members of Council and Members of the Town`s local boards and committees. The Integrity Commissioner also provides advice and education on matters related to the Municipal Conflict of Interest Act.
Where it is in the public interest to do so, the Integrity Commissioner will conduct inquiries in response to a complaint regarding whether a member has contravened their respective Code of Conduct, Town policies, procedures, protocols and rules relating to ethical conduct of Members, or section 5, 5.1, or 5.2 of the Municipal Conflict of Interest Act.
The Integrity Commissioner is an independent statutory officer, whose role is to provide an impartial review and investigation into ethical complaints received from the public.
What is the purpose of having an Integrity Commissioner?
The Integrity Commissioner’s role mandated by the Municipal Act as of March 1, 2019, is to serve as an independent advisor on ethical matters, provide advice to Members of Council and investigate public complaints.
Is the work of the Integrity Commissioner directed by the Town?
No. The Integrity Commissioner operates independently. Reports and findings are provided to Town Council and are public, subject to issues of confidentiality.
What qualifies as a complaint?
Any member of the public believing an ethical breech has occurred by a member of Town Council may issue a complaint (please refer to Informal Complaint Procedure guidelines, and Formal Complaint Procedure process).
Can complaints against Town staff be submitted to the Integrity Commissioner?
No. Per the Municipal Act, the Integrity Commissioner is to respond only to complaints against Members of Town Council.
What happens when a formal complaint is submitted?
The Integrity Commissioner will review and contact the person who submitted the complaint and determine whether a breech has occurred. Depending on the circumstance/severity/complexity of the complaint, the Integrity Commissioner will conduct an investigation which may include requesting and reviewing specific materials and/or interviewing the subject of the complaint and witnesses. The findings of the investigation are reported back to Town Council and the complaint initiator.
Can I remain anonymous if I submit a complaint?
No. Persons submitting a complaint must identify themselves in order for the Integrity Commissioner to determine the validity of the complaint and whether an investigation will proceed.
Informal Complaint Procedure
Any person or representative of an organization who has identified or witnessed behaviour or an activity by a member of Council that they believe is in contravention of the Council Code of Conduct (the “Code”) may wish to address the prohibited behaviour or activity themselves as follows:
Advise the member that the behaviour or activity contravenes the Code;
Encourage the member to stop the prohibited behaviour or activity;
Keep a written record of the incidents including dates, times, locations, other persons present, and any other relevant information;
If applicable, confirm to the member your satisfaction with the response of the member; or, if applicable, advise the member of your dissatisfaction with the response; and
Consider the need to pursue the matter in accordance with the formal complaint procedure outlined in the Code of Conduct, or in accordance with another applicable judicial or quasi-judicial process or complaint procedure.
All persons and organizations are encouraged to initially pursue this informal complaint procedure as a means of stopping and remedying a behaviour or activity that is prohibited by the Code. With the consent of the complaining individual or organization and the member, the Integrity Commissioner may be part of an informal process. However, it is not a precondition or a prerequisite that those complaining must pursue the Informal Complaint Procedure before pursuing the Formal Complaint Procedure.
Formal Complaint Procedure
A request for an investigation of a complaint that a member has contravened the Code of Conduct shall be sent directly to the Integrity Commissioner via e-mail by completing the following complaint form. Pages 34 & 35 of the Code of Conduct for Members of Council outlines what should be included in the complaint.