Manage a conflict of interest disclosure in the BC Public Service
Managers and supervisors (including ethics advisors and Deputy Ministers) in the BC Public Service are responsible for setting a high standard of integrity, consistency, transparency and accountability.
Managers and their employees are required under the Standards of Conduct to report and address conflicts of interest.
As noted in the Assessing & Addressing Conflicts of Interest: Guidelines for Managers, Ethics Advisors and Deputy Ministers (PDF, 321KB), managers have an obligation to assess and address conflicts of interest that may come up at work. Often, managers are able to resolve simple and straight-forward issues with the employee in an informal way. Sometimes, a more formal assessment and decision is required. Before you look to resolve any conflict, it is important to know who makes decisions about conflicts of interest in your ministry. You can determine who has the authority to make these decisions by asking your supervisor or executive, searching for a human resource or decision delegation matrix on your ministry intranet site, or ask your ministry ethics advisor.
Resolving conflicts informally
If an employee comes forward with a simple or straightforward concern about a possible conflict of interest, managers can resolve the issue informally by having a conversation with their employee. Following the conversation, the discussion and decision should be documented.
An employee might be concerned that their private business selling eggs from their hobby farm at a local Sunday market might constitute a conflict of interest. Their manager could decide informally that this does not create a conflict of interest. On the other hand, a manager might advise an employee that they cannot participate in a job competition where one of the applicants is the employee’s sister, as this would constitute a conflict.
Resolving conflicts formally using the Employee Disclosure form
If an employee comes forward with a concern about a possible conflict of interest that cannot be resolved informally, they must formally disclose information about the conflict to their manager using the employee disclosure form. Managers are responsible for reviewing the information submitted in the disclosure form and making determinations, often in consultation with their ministry ethics advisor and/or the BC Public Service Agency Policy Branch, to address and resolve the conflict disclosed by their employee.
The discussion and decision should be documented using the manager disclosure form, and the decision must be formally communicated to the employee in writing. The manager's disclosure form, the employee's disclosure form and letter, and any other documentation (such as legal advice or email exchanges) should be submitted to the employee's personnel file at the BC Public Service Agency.
Refer to Assessing & Addressing Conflicts of Interest: Guidelines for Managers, Ethics Advisors and Deputy Ministers (PDF, 321KB) for detailed information about the different types of conflict of interest, as well as the assessment and resolution of possible conflicts of interest.
Key criteria for review
When reviewing an employee-submitted disclosure, managers and ethics advisors should ensure the employee has disclosed:
- The specific job or public duties of the employee relevant to the possible conflict
- The specific private interests of the employee relevant to the possible conflict
- Actions the employee has taken, or will take, to mitigate any conflict between their job/public duties and their private interests