If an employee comes to you about a possible conflict of interest, it is important to understand your role and responsibilities in the assessment process:
Following the disclosure of a possible conflict of interest issue by an employee as required by the Standards of Conduct (or in rare cases, identification of a possible conflict by someone other than the employee concerned) an assessment by the employer must be made to determine if a real, potential or perceived conflict exists, and decisions made regarding what steps (if any) should or can be taken to address the conflict. Managers, Ministry ethics advisors and the BC Public Service Agency may all play a role in this process.
A detailed description of the assessment process can be found in the Assessing and Addressing Conflicts of Interest Guidelines for Managers, Ethics Advisors and Deputy Ministers (PDF, 468KB)
Employees are required under the Standards of Conduct to disclose information to their manager/supervisor regarding circumstances that may give rise to a real, perceived or potential conflict of interest. Employees may raise potential conflicts informally during a supervisory meeting, via email, or formally using the employee disclosure form.
Employees may raise simple or straightforward issues. Supervisors or managers may resolve the conflict informally by way of a conversation with the employee. The supervisor should document the conversation, the decision, and any direction to take specific steps to resolve or mitigate the conflict.
An employee may choose to complete and send the employee conflict of interest disclosure form. Managers may ask employees submit the conflict of interest disclosure form. This form helps employees organize their thinking and provide an overview of the situation, their job duties, and identify areas of overlap or possible conflict.
To determine whether a conflict of interest may exist, supervisors must identify:
For more information, refer to Assessing & Addressing Conflicts of Interest: Guidelines for Managers, Ethics Advisors and Deputy Ministers (PDF, 321KB)
Managers should analyze whether an employee's private interests conflict, or could be perceived to conflict, with the ability to discharge their work duties or serve the public interest, and assess the severity of harm that could result. Analysis and assessment should be complete within approximately two weeks after the receipt of an employee's disclosure.
If a manager is unsure whether there is a conflict, whether mitigation or resolution is possible, or whether they have the authority to decide on a possible conflict of interest, they should contact their executive or ethics advisor for assistance. It may be appropriate at this stage in the process to seek out the advice of the executive, ministry ethics advisor, or the Policy Branch at the BC Public Service Agency.
It is important to document the assessment and decision related to an employee's claim. Steps can be recorded in the Manager's Disclosure form. Documentation will include:
If the manager disclosure form has been completed (including a copy of the employee disclosure form and the communication of the decision and directions to the employee), then once the manager submits the form, a copy will automatically be sent to the employee’s personnel file. No further action is required.
If the process was initiated informally, or using a PDF copy, then the manager should submit a ticket on AskMyHR, attaching all related documentation for the employee’s personnel file.
If you have questions, or need clarification on what to do next, please contact your Supervisor or Ministry ethics advisor