Addressing misconduct and wrongdoing at Indigenous Services Canada: First annual report: 2024-2025 fiscal year

The role of employees

All employees and managers in the department play a part in ensuring that our workplace is:

• healthy
• respectful
• safe
• accessible
• free of harassment, violence and discrimination

We are also all responsible for adhering to and living by the Values and Ethics Code for the Public Sector, as well as ISC's Values and Ethics Code.

What you can do about misconduct

Any employee who is directly or indirectly affected by an instance of misconduct or wrongdoing can and should make this known, no matter the level or occupation of the individual responsible. No one should be afraid of reprisal or punishment for doing what is right and they should know that their privacy will be respected and protected.

ISC employees have many options for reporting allegations misconduct or wrongdoing, including informal conflict resolution mechanisms and a range of formal mechanisms. This report focuses on formal resolution mechanisms.

Where to turn for help

In all instances, an employee's first point of contact should be their manager, unless the manager is the source of the issue. A table at the end of this document sets out information on the different kinds of incidents and situations that employees can report, along with the resources available and the possible avenues to choose in each case.

All complaints are taken seriously

Above all, ISC employees should know that all complaints and allegations of misconduct and wrongdoing are taken seriously, assessed and, if proven founded, followed up with administrative or disciplinary actions in a timely fashion.

General approach

Employees who experience or witness misconduct or suspected wrongdoing can use different recourse processes.

ISC reviews all cases of suspected misconduct or wrongdoing and follows the Government of Canada's Policy on People Management and Guidelines for Discipline.

This includes:

• conducting fair and objective investigative processes as needed and as expeditiously as possible
• taking all measures to protect the confidentiality of the information collected and the privacy of individuals involved
• ensuring that there is procedural fairness for all

We decide if allegations of wrongdoing or misconduct are founded based on the available facts.

If the initial information is not enough, we start an investigative process. This may be:

• a fact-finding exercise: used for straightforward situations where the facts are clear and only limited review is needed
• a formal investigation: used for more complex cases where more information is required

Actions taken in founded cases of misconduct and wrongdoing

As an employer, ISC has a responsibility to ensure that appropriate actions are taken when misconduct or wrongdoing is determined to be founded.

These actions can be administrative or disciplinary in nature.

Disciplinary measures may range from:

• oral reprimand
• written reprimand
• suspension
• financial penalty
• demotion
• termination
• other disciplinary measures as appropriate

Measures are determined by considering any aggravating or extenuating circumstances. The application of disciplinary measures seeks to correct behaviours and is generally progressive, increasing in severity with successive acts of misconduct. In some cases, the misconduct may be sufficiently serious to warrant severe action, even on a first offence.

Administrative measures are taken to make the necessary adjustments to a situation. This includes, for example:

• placing an employee on leave without pay if they were absent without authorization
• noting the unacceptable behaviour's impact in performance appraisals
• clawing back executive performance pay when applicable
• temporarily removing human resources or financial delegation
• other actions as appropriate and depending on the situation

Administrative measures can also be used to provide tools to the employee with a view to ensuring the misconduct does not happen again, for example, by:

• developing an action plan for them to change their behaviour
• giving them training or coaching
• scheduling regular meetings with management, etc.

Some situations may require the application of one or several administrative measures.

In some instances, a situation may warrant the application of both administrative and disciplinary measures.

Fraud and financial misconduct cases

One investigative process was completed over the period. It concluded that financial misconduct had occurred:

• an employee committed time theft during the probationary period. The employee was suspended without pay

One investigative process was completed over the period. It concluded that:

• The employee exhibited fraudulent conduct through willful misrepresentation and deliberate concealment of material facts with the intent of gaining a dishonest private advantage. The employee used their position to facilitate the awarding of contracts and engaging in bid-rigging to benefit family members. The employee also tried to purchase a Crown-owned property using privileged information. The employee was terminated and recommendations for strengthening internal controls were provided to the affected workplace

Harassment and workplace violence cases

During the 2024-2025 fiscal year, three investigative processes were completed. They concluded that none of the allegations met the definition of harassment or workplace violence:

• Allegations related to roles, responsibilities, allegations of aggressive, threatening behaviour, allegations of inappropriate access to belongings or computers, allegations of inappropriate and sexual comments:
  • Result: It is not concluded that the responding party engaged in an occurrence of harassment and violence
• Continued admonishment and aggression, humiliation and denigration, isolation in the workplace:
  • Result: In this case, the responding party exercised their management rights within the scope of those rights and did so fairly and in good faith...does not meet the definition of harassment and violence. The notice of occurrence is unfounded
• Withholding resources, intimidation, undermining work and idea, inappropriate facial gestures, persistently critiquing, undermining or belittling, yelling or making aggressive gestures, demeaning, ridiculing a person:
  • Result: The notice of occurrence complaint falls under exempt behavior of reasonable management action and are not defined as harassment under Bill C-65

Values and Ethics Code cases

Throughout the fiscal year, eight investigative processes were completed, all of which concluded that a breach of the Values and Ethics Code had occurred:

• An employee failed to comply with the departmental, Public Sector and ISC Values and Ethics Codes by not adhering to prevention and control protocols during an event. The employee received a written reprimand
• Following a management-led meeting an employee engaged with a department's expert after being informed that such consultation was not required. They received a written reprimand
• An employee misused a travel credit card by using it to charge items of a personal nature. They received a written reprimand
• An employee worked intermittently from another country over a three-year period without authorization and was dishonest with management. The employee received a written reprimand
• An employee demonstrated inappropriate behavior towards a colleague in the workplace, including yelling. The employee received an oral reprimand
• An employee's microphone was on during a team meeting and the employee made inappropriate comments regarding their supervisor's appearance and demeanor. The employee received an oral reprimand
• An employee engaged in misconduct by providing a professional opinion in a legal proceeding while referencing their public service role and experience, leveraging their government position to enhance credibility. The employee failed to follow conditions to report a potential conflict of interest and the external activity was ultimately deemed a conflict of interest. The employee was suspended without pay
• An employee was the subject of allegations involving repeated inappropriate and disrespectful comments toward colleagues, contributing to an unhealthy and unsafe work environment. The employee also allegedly failed to demonstrate respect and integrity in interactions with a client. The employee received a written reprimand

Administrative misconduct cases

Over the fiscal period, 23 investigative processes were completed, all of which concluded that administrative misconduct had occurred:

• Six situations were related to absenteeism, with employees failing to report leave to management or entering leave into the system. In five of the situations, the employees were suspended without pay, and one employee received a written reprimand
• Five situations were related to unauthorized absences. In three of the situations, the employees were late to work and did not contact their supervisors. In one case, the employee requested leave which was denied and the employee failed to report to work. In one situation, an employee failed to report to work on separate occasions within a short period of time without obtaining authorized leave. In all instances, the employees were suspended without pay
• An employee falsified documentation related to overtime and was suspended without pay
• An employee permitted an unauthorized individual to operate a government-assigned vehicle which resulted in a car accident requiring intervention and vehicle seizure. The employee failed to report the incident and was suspended without pay
• An employee displayed insubordinate behaviors. There were multiple occasions when the employee did not comply with their letters of expectation. The employee was suspended without pay
• An employee's misconduct involving civilians outside the workplace resulted in criminal charges being laid against the employee. The employee was terminated
• An employee was given paid education leave to complete some mandatory training but failed to complete them. The employee also failed to follow appropriate protocol to dispense a controlled substance. The employee failed to attend to a fact finding meeting and received a written reprimand for their actions
• An employee failed to follow workflow priorities and complete assigned tasks. The employee received a suspension without pay
• An employee violated workplace policy by using a fleet vehicle for personal purposes and incurring a speeding ticket. The employee received an oral reprimand
• An employee used the name of a colleague on a formal record, suggesting an order had been provided, without prior consultation with said colleague. The employee received a written reprimand
• An employee demonstrated inappropriate behavior and made unacceptable comments toward their manager following a meeting in which a Letter of Expectation was issued. The employee's actions were found to be in violation of the expectations outlined in that letter. The employee received a written reprimand
• An employee admitted using inappropriate gestures and language towards another individual. The employee's conduct was deemed unprofessional and inappropriate by management. The employee received a written reprimand
• An employee breached the Values and Ethics Code, the Canadian Federal Public Service Policy on Service and Digital and their telework agreement by failing to disclose their intention to cross the Canadian border with government property and work from an unauthorized international location. Despite being reminded on separate occasions of the telework restrictions, the employee proceeded without approval. The employee was suspended without pay
• An employee engaged in inappropriate and disrespectful workplace behavior, including harassment. Their conduct, particularly involving unprofessional communication, was found unacceptable and had an impact on colleagues. The employee received a written reprimand

Security Screening Review for Cause

Over the fiscal year 2024-2025, no reviews for cause were completed.

The Corporate Security Management Directorate (CSMD) would initiate a review for cause of the security status or clearance previously granted to an individual when:

• Information is uncovered or reported about an individual that may call into question their reliability or loyalty to Canada
• Adverse information reflects:
  • Recent questionable judgment or dishonesty
  • A recurring pattern of questionable judgment or dishonesty

When conducting a review for cause, in accordance with subsection F.2.2.11 of Appendix F: Mandatory Procedures for Security Screening Decisions and Notifications, pending the outcome, CSMD will consider a decision to suspend:

• A security status or clearance
• Access to sensitive information and assets, including IT systems and facilities

Security Administrative Investigations

Over the fiscal year 2024-2025, no security administrative investigations were completed.

The CSMD will initiate a security administrative investigation following a reported incident or allegation involving an employee and a potential security concern. This process begins with an initial fact-finding exercise to determine whether a formal investigation is warranted. The steps are:

• Conduct initial fact-finding to assess if a security administrative investigation is justified
• If warranted, the Chief Security Officer will authorize the investigation and sign the terms of reference
• Formal notification letter will be issued to the individuals under investigation
• Recommendation to suspend the individual(s) during the investigation may be considered, depending on the nature of the concern
• Upon completion, a final investigation report will be provided to management for review and action

Some security measures could be recommended.

Violations of ISC Network Acceptable Use Policy cases

In 2024-2025, there was one situation of violation of the ISC Network Acceptable Use Policy investigated and was determined to be founded:

• An employee engaged in misconduct by inappropriate content with colleagues following a team meeting. The employee received an oral reprimand

In 2024-2025, there were 21 incidents of unauthorized access to the department's network while traveling internationally. For example, logging into a departmental laptop.

The following steps were taken:

• Upon confirmation of an unauthorized login, Cyber Security disabled the user's AD account
• Access control was updated to ensure the account could not be re-enabled without proper authorization
• Cyber Security notified CSMD to log and track the incident appropriately
• The employee's manager was informed of the incident
• Further action was deferred until the employee returned from their travel
• Upon the employee's return, potential actions included fact-finding, a security administrative investigation and targeted security awareness measures
• Follow-up actions were carried out in collaboration with relevant stakeholders and key partners

Violations of the Treasury Board Secretariat Policy on Unacceptable Network and Device Use

The Cyber Security Directorate reported 38 violations of the Treasury Board Secretariat (TBS) Policy on Unacceptable Network and Device Use between April 1, 2024, and March 31, 2025. Employees were found using corporate devices to download unauthorized applications, leading to user awareness sessions and instructions to uninstall these applications. The Cyber Security Directorate, under the Chief Finances Results Delivery Office, is responsible for monitoring endpoints, incident response and ensuring confidentiality and integrity of information.

Notable incidents include:

• Employees downloaded and executed unauthorized applications on Government of Canada devices. In all instances the employees and their managers were contacted. The employees were provided user awareness and instructions to uninstall the unapproved applications
• Examples of detections:
  • One instance where the employee was identified as attempting to circumvent cyber security controls attempting to install remote access software which would allow the user to connect remotely to devices through the internet or allow their Government of Canada device to be remotely accessed from outside the corporate network. The software was removed
  • Three instances where entertainment applications, for example, games were downloaded and installed. The software was removed
  • One instance where the user downloaded software which prevented the computer from becoming idle. The software was removed

This list is not exhaustive. Cyber Security's tracking of the type of incidents is being matured.

External investigations

Other Canadian entities also undertake their own investigations of our department or staff members as part of their mandate. While no such investigations occurred over the 2024-2025 period, this section provides a summary of the possible types of investigations and the external entities responsible for investigating alleged misconduct and wrongdoing by an ISC employee.

Office of the Public Sector Integrity Commissioner

The Office of the Public Sector Integrity Commissioner of Canada is an independent federal organization that was established to implement the Public Servants Disclosure Protection Act. The office investigates wrongdoing in the federal public sector and helps protect whistleblowers, those who make a protected disclosure of wrongdoing and those who participate in investigations from reprisal.

The Office contributes to strengthening accountability and increases oversight of government operations by:

• providing an independent and confidential process for receiving and investigating disclosures of wrongdoing in, or relating to, the federal public sector from public servants and members of the public
• reporting founded cases of wrongdoing to Parliament and making recommendations to chief executives on corrective measures
• providing a mechanism for handling complaints of reprisal from public servants and former public servants for the purpose of coming to a resolution, including through conciliation and by referring cases to the Public Servants Disclosure Protection Tribunal

During the past fiscal year, no reports related to Indigenous Services Canada have been published.

Canadian Human Rights Commission

Under the Canadian Human Rights Act, Canadian human rights complaints relate to any action or a decision that results in the unfair or negative treatment of a person under the prohibited grounds of discrimination, such as:

• race, national or ethnic origin, colour
• religion
• age
• sex
• sexual orientation, gender identity or expression
• marital status, family status
• genetic characteristics
• disability
• conviction for an offence for which a pardon has been granted or in respect of which a record suspension has been ordered

These can be brought up as grievances through the employee's union, or directly as a complaint to the Canadian Human Rights Commission (CHRC). Once a human rights complaint is filed with the CHRC by an employee, Labour Relations reviews the complaint and coordinates the departmental response to the CHRC. In the 2024-2025 fiscal year, there were no completed CHRC investigations.

Employment and Social Development Canada

EEmployment and Social Development Canada investigations relate to the department's occupational health and safety program and workplace. Investigations can be initiated under three circumstances:

• in the event of a critical injury or a fatality
• after a complaint under the Canada Labour Code section 127.1, Internal Complaint Resolution Process: an employee believes that there has been a contravention of part roman numeral 2II of the Code and that an accident, injury or illness can or has occurred
• after a complaint under the Canada Labour Code section 128.1, Refusal to work if danger: if the employee is not satisfied with ISC's decision and believes there is still a danger for their health

In these circumstances, Employment and Social Development Canada can proceed as follows:

• request that the employer or employee submit an assurance of voluntary compliance
  • an assurance of voluntary compliance is the employer or employee's written commitment to a health and safety officer that a contravention of the Canada Labour Code will be corrected within a specified period
• issue a legal written notice ordering the employer or employee to address a contravention of part roman numeral 2II of the Code within a specified period

The department had no infractions under part roman numeral 2II of the Canada Labour Code in 2024 to 2025.

ISC Ombuds Office

The Ombuds Office provides a confidential, informal, impartial and independent space for ISC employees to discuss workplace issues and concerns. The Ombuds Team supports the parties involved as they decide outcomes and how best to achieve them. It provides a culturally safe space that empowers employees to find practical solutions to their problems and it acts to give independent, unbiased perspectives and timely feedback to the organization on the impacts of decisions, actions and behaviours on ISC employees.

To learn more, employees may contact the Ombuds: ombuds@sac-isc.gc.ca

Workplace Harassment and Violence Prevention

The Workplace Harassment and Violence Prevention Regulations identifies the Designated Recipient as responsible for receiving and responding to all reports of workplace harassment and violence as prescribed in the Canada Labour Code. Canada Labour Code investigations focus on the workplace and do not lead to individual administrative or disciplinary actions. However, the delegated manager, in consultation with Labour Relations, can also initiate a separate process to determine if administrative or disciplinary measures are warranted. This may require a separate investigation.

At ISC, the Harassment and Violence Prevention (HVP) team has been named as the designated recipient for ISC.

The team offers guidance and advice to managers and employees, develops guidelines and tools, and provides training with a focus on prevention initiatives and provide recommendations to prevent any reoccurrence of harassment in the workplace.

To learn more, contact hvprevention@sac-isc.gc.ca

The Centre for Values and Ethics

If you want to ask questions about the Values and Ethics Code, to submit a Conflict of Interest form, to get clarification on general Values and Ethics questions, or to submit a Disclosure of Wrongdoing, consult the Centre for Values and Ethics.

The Centre for Values and Ethics is responsible for creating awareness and promoting ISC's Values and Ethics Code and to provide orientation and guidance on an array of topics related to conflicts of interest, such as the application of post-employment restrictions for designated positions, the receipt of gifts, personal and familial relationships, outside employment or activities and political activities. The centre also ensures investigations are conducted under the Code, when warranted.

Investigations under the Code begin with a complaint of alleged breaches on matters that could be either personal or departmental in nature. In this process, the confidentiality of the complainant's identity is not guaranteed. Findings resulting from an investigation under the Code may be founded, unfounded or inconclusive. The decision to investigate is usually made within 45 days after formal disclosure.  Investigations usually take 12 months to complete.

In cases where the allegations are founded, the respondent's delegated authority is responsible for taking appropriate redress measures, up to and including dismissal.

Finally, under the Public Sector Disclosure Protection Act, the centre is also the department's Senior Officer for Internal Disclosure and ensures investigations take place where there is reason to believe wrongdoing occurred.

The Public Sector Disclosure Protection Act gives federal public sector employees and others a secure and confidential process for disclosing wrongdoing in the workplace as well as protection from acts of reprisal. It is part of the Government of Canada's ongoing commitment to promoting ethical practices in the public sector.

Employees may make a protected disclosures to the Senior Officer for Internal Disclosure, to their supervisor or to the Public Sector Integrity Commissioner of Canada.

The Senior Officer for Internal Disclosure's mandate is:

• receive and address disclosures from ISC employees
• ensure the confidentiality of all information obtained under disclosures
• provide Public Sector Disclosure Protection Act - related advice and guidance to ISC employees
• investigate allegations of wrongdoing
• promote ethical practices in the public sector and a positive environment for disclosing wrongdoing

To learn more or to schedule a meeting with the Senior Officer for Internal Disclosure to report alleged wrongdoing, contact valeursethique-valuesethics@sac-isc.gc.ca.

Labour Relations Division

If you are a manager seeking guidance on challenging situations with an employee, on employees' rights, interests, limitations and capacities, contact Labour Relations.

The mandate of the Labour Relations Centre of Expertise is to promote harmonious and productive workplace relations by providing expert advice and assistance to managers on labour relations matters. To that end, Labour Relations Division delivers numerous services to help managers and employees create and maintain a workplace that is conducive to the achievement of departmental objectives. These services include developing directives, guidelines and tools to promote good people management practices and initiatives.

One of Labour Relations Division's services is to provide guidance and advice to managers when an administrative investigation or fact-finding inquiry into allegations of misconduct is warranted or required. This includes ensuring that managers address breaches or violations of a policy or code, acts of insubordination, breaches of trust or any other unacceptable behaviour.

Following a labour relations investigation, a discipline process may be required to address allegations that are founded. To that end, Labour Relations Division is responsible for assisting delegated managers to ensure that the discipline process is fair and transparent and that it respects the rules of procedural fairness. In some circumstances, a disciplinary hearing may be initiated without the need for an administrative investigation. This would occur when the facts in a case are clear and known by all parties involved.

To learn more, managers may contact relationsdetravail-labourrelations@sac-isc.gc.ca.

Assessment and Investigation Services Branch

Assessment and Investigation Services Branch (AISB), is responsible for investigating allegations of potential fraud and financial misconduct related to department funding agreements to First Nations. As part of these efforts, AISB performs the following:

• Conduct investigations into allegations received from Indigenous community members, public servants, or other sources concerning the management of departmental funding, support internal oversight activities, and provide advisory and referral services for complaints
• Leads investigations related to the use of departmental grants and contributions funding by external recipients and departmental programs
• Prepare a forensic report that identifies potential recoveries, provides recommendations to senior management on strengthening internal controls, and make referral to administrative investigations for potential misconduct or criminal investigations

For more information, please contact:
Email: cnap-nacc@rcaanc-cirnac.gc.ca, or
Phone (toll-free): 1-855-504-6760

Corporate Accounting, Systems and Operations Branch

Corporate Accounting, Systems and Operations Branch (CASO) coordinates fraud risk assessments at the departmental level as part of its internal controls ongoing monitoring strategy and makes recommendations to senior management on strengthening internal controls. CASO is also responsible for reporting losses of public money and property in its submissions to the annual Public Accounts of Canada and for coordinating responses to the fraud risk questionnaire issued by the Office of the Auditor General as part of its annual audit of ISC's Public Accounts.

For more information, please contact capic-admin@sac-isc.gc.ca

Corporate Security Management Directorate

Corporate Security Management Directorate (CSMD) plays a central role in ensuring the protection of employees, information and assets. Their responsibilities align with the TBS Policy on Government Security and support the broader departmental security program under the leadership of the Chief Security Officer.

The following outlines CSMD's responsibilities for assessing and investigating security events, including circumstances that may affect an individual's eligibility for, or continued holding of, a Reliability Status or Security Clearance:

• Evaluate and respond to situations that may affect an individual's suitability to access sensitive information, assets, or facilities. This includes conducting reviews of significant changes in personal circumstances or incidents that raise concerns about an individual's trustworthiness, reliability, or loyalty. Security measures such as suspending or revoking security status or clearance may be implemented as required
• Conduct impartial, thorough and timely administrative investigations into security-related events, breaches, or concerns involving employees, contractors or operations. These investigations may address unauthorized disclosures, compromised protected or classified information or breaches of security protocols. Security administrative investigations are conducted in collaboration with key security partners. Security investigation reports will be shared with relevant stakeholders, including findings and recommended security measures for management
• Promote security awareness across the department to help reduce reviews for cause and administrative investigations. This involves ensuring employees understand their responsibilities, follow protocols and recognize potential risks. By fostering accountability and timely reporting, security awareness helps prevent incidents

To report a security event, employees are required to complete the Security Event Report and return the completed form to the Security Operations Team. Once the report is received, CSMD will review the information and communicate the next steps.

For any questions or concerns, you may also contact the Security Operations Team directly.

Cyber Security Directorate

Cyber Security Directorate is under the authority of the Office of the Chief Financial Officer and is responsible for the monitoring and protection of endpoints, executing incident response processes, performing pro-active threat hunting, conducting human resources and labour relations fact finding requests and overall ensuring the confidentiality, integrity and availability of information.