12-21COUNTY OF ELGIN
By-Law No. 12-21
"BEING A BY LAW TO APPROVE A COMPLAINT FORM FOR MUNICIPAL
INVESTIGATION OF CODE OF CONDUCT BY AN INTEGRITY COMMISSIONER
PURSUANT TO SECTION 223.3 OF THE MUNICIPAL ACT, 2001, S.O. 2001, C.25,
AS AMENDED"
WHEREAS County Council has revised its Code of Conduct and appointed an
Integrity Commissioner who is responsible for performing in an independent manner
functions related to the Code of Conduct of members of Council and local boards; and
WHEREAS Section 391.(3) and (4) of the Municipal Act, 2001, S.O. 2001, c.25, as
amended, authorizes a municipality to impose a fee or charge including costs incurred by
the municipality related administration; and
WHEREAS it is deemed appropriate to develop a standard complaint form to be
used for said investigations;
NOW THEREFORE BE IT RESOLVED THAT the Municipal Council of the
Corporation of the County of Elgin hereby enacts as follows:
1. THAT every request for an investigation shall be initiated through the submission of
a Municipal Investigation Code of Conduct Complaint Form in the form attached as
Schedule "A" hereto and forming part of this by-law.
2. THAT this by-law shall come into force and take effect on September 1, 2012.
READ A FIRST, SECOND AND THIRD TIME AND FINALLY PASSED THIS 24TH DAY OF
JULY 2012.
rk G. McDonald
Chief Adnninistra ive Officer.
Bill Walters,
Warden.
SCHEDULE "A"
By -Law No. 12 -21
COMPLAINT FORM
MUNICIPAL INVESTIGATION OF CODE OF CONDUCT
by
Integrity Commissioner
IN ACCORDANCE WITH
Section 223.3 of the Municipal Act 2001
(As Amended)
A FEE OF $25.00 MUST ACCOMPANY THIS FORM PRIOR TO BEING PROCESSED.
PLEASE FORWARD COMPLETED FORMS TO:
John Maddox
JGM CONSULTING
#42 — 99 Edgevalley Road
London, Ontario N5Y 5N1
POLICY FOR CODE OF CONDUCT INVESTIGATIONS
Policy Statement
The County of Elgin (the municipality) is committed to ensuring that a request for an
investigation under Section 223.3 of the Municipal Act, 2001 as amended (the Act) is dealt
with in a fair, open and expeditious manner.
The municipality commits to full co-operation including the provision of all information
requested by the Integrity Commission (the Investigator), either written or through
interviews, to assist the Investigator in his investigations.
This policy shall be posted on the municipal website and available from the Chief
Administrative Officer's Office (the Clerk), 450 Sunset Drive, St. Thomas, ON, N5R 5V1 or
by contacting the Administrative Services Department at 519-631-1460 or through e-mail
to mpaylerelgin-county.on.ca
This policy applies to all appointed Boards as defined in the Municipal Act.
Background:
Through By-Law No. 12-20 the municipality has appointed Mr. John Maddox as a
Municipal Integrity Commissioner and authorized him to conduct investigations upon
receipt of a complaint in respect of complaints regarding the County of Elgin's Code of
Conduct. (see Appendix 2 for Duties of Integrity Commissioner)
Complaints Procedures: (see Appendix 3 for Complaint Protocol)
Individuals are encouraged to speak directly with the individual regarding a Complaint in
order to resolve any concerns prior to beginning the formal complaint process. (see
Appendix 1 for Informal Complaint Procedure)
Individuals may submit complaints to the Investigator relating to compliance with the Code.
All complaints will be treated as confidential, unless authorization is given by the
complainant to release his or her identity.
Every request for an investigation shall be initiated through the submission of the
"Municipal Investigation Complaint Form" ("Complaint Form") provided. The said
Complaint Form shall be made available to the public through the Clerk's Office or can be
downloaded from the County website at www.elgin-county.on.ca. Completed Complaint
Forms will not be accepted by facsimile, e-mail or other electronic means.
A completed Complaint Form shall be submitted to either the Clerk's Office or directly to the
Integrity Commissioner and shall be accompanied by payment of an administrative/
processing fee of $25.00, payable in cash or bank draft to the Corporation of the County of
Elgin, in accordance with the following:
2
• By delivery to the Clerk in a sealed envelope clearly identified as a Complaint
under Section 223.3 of the Municipal Act (Code of Conduct Complaint)
Or
• By mail directly to:
John Maddox, Municipal Closed Meeting Investigator
99 Edgevalley Road, Unit #42
London, Ontario
N5Y 5N1
Inquiries only may be submitted by email to John Maddox: maddoxiosympatico.ca or
by telephone at 519-951-0330 during regular office hours.
A completed Complaint Form will not be accepted unless accompanied by payment of the
required administrative/processing fee.
In the event that the investigator concludes that there is no basis for the complaint then
the said administration processing fee shall be refunded to the submitting Complainant.
All complaints must be made in writing using the Affidavit: (Appendix 4)
When complaints are submitted directly to the Clerk, the Clerk shall follow the following
procedures:
1. Take all measures to ensure the envelope remains sealed and its contents remain
confidential;
2. Assign a file number and record said file number on the envelope;
3. Log the file number together with the date and time received;
4. Forward, forthwith to the Investigator by regular mail.
Appendix 1
INFORMAL COMPLAINT PROCEDURE
Individuals (for example, municipal employees, members of the public, members
of Council or local boards (restricted definition), or organizations (including local
boards (restricted definition) who have identified or witnessed behaviour or an
activity by a member of Council or a local board (restricted definition) that they
believe is in contravention of the Code of Conduct for Members of Council and
Local Boards (Restricted Definition) the "Code of Conduct" would address the
prohibited behaviour or activity themselves as follows:
(1) advise the member that the behaviour or activity contravenes the Code of
Conduct;
(2) encourage the member to stop the prohibited behaviour or activity;
(3) keep a written record of the incidents including dates, times, locations, other
persons present, and any other relevant information;
(4) tell someone else (for example, a senior staff member or an officer of the
organization) about your concerns, your comments to the member and the
response of the member;
(5)
if applicable, confirm to the member's satisfaction with the response of the
member; or, if applicable, advise the member of your dissatisfaction with the
response; and,
(6) consider the need to pursue the matter in accordance with the formal
complaint procedure or in accordance with another applicable judicial or
quasi-judicial process or complaint procedure.
Individuals 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 of Conduct. With the consent of the
complaining individual or organization and the member, the Integrity
Commissioner may be part of any informal process. However, it is not a
precondition or a prerequisite that those complaining pursue the informal
complaint procedure prior to pursing the formal complaint procedure.
Appendix 2
DUTIES OF A MUNICIPAL INTEGRITY COMMISSIONER
The Integrity Commissioner shall perform the duties and have the powers provided for in
the Act, including but not limited to the following:
(1) Advisory: upon proper request, provide written and/or verbal advice to individual members
of Council respecting the application of the Code of Conduct and/or any other procedures, rules,
and policies relating to and reflecting upon their ethical behavior, including but not limited to
general interpretation of the Municipal Conflict of Interest Act (Ontario); and furthermore and
when appropriate, providing the full Council with specific and general opinions and advice
respecting compliance by elected officials in respect of the provisions of governing statues the
Code of Conduct and any other applicable procedures, rules, and policies.
(2) Compliance Investigation/Determinations: upon proper request from a member of Council
or local board, municipal administration or one or more members of the public, to conduct an
inquiry and make a determination as to any alleged contravention of the Code of Conduct or
applicable procedures, rules, and policies by a member of Council or local board and, thereafter,
to report the details and results of such inquiry to municipal Council.
(3) Educational: provide the Chief Administrative Officer or as directed with an annual report
of activities during the previous calendar year as Integrity Commissioner, including but not
necessarily limited to advice given to Council or individual members of Council and a summary
of inquiry results and determinations; furthermore, provide outreach programs to members of
Council and local boards and relevant staff on legislation, protocols, and office procedures
emphasizing the importance of compliance with a Code of Conduct for public confidence in
Municipal Government; and, furthermore, dissemination of information available to the public on
the website operated by Elgin.
Notwithstanding that set forth above, the parties acknowledge and agree that the function of the
Integrity Commissioner is to provide advice and opinion to Council and members thereof, to
provide independent complaint prevention, investigation, adjudication, and resolution to
members of Council and the public, and education respecting adherence with the Code of
Conduct for members of Council and other procedures, rules, and policies governing ethical
behavior.
The parties hereto also acknowledge and agree the Integrity Commissioner, will perform
services, and in particular those services relating to advisory and educational duties, in a
manner so as to avoid duplicated advice, opinion, and cost in respect of identical requests and
inquiries — for example, the Integrity Commissioner shall decline to provide individualized advice
and opinion to more than one member of Council or a local board on identical issues but should
choose to provide general advice to Council or such local board as a whole to answer all such
inquiries. In addition, it is recognized that the Integrity Commissioner, will likely receive requests
for advice on matters involving compliance with the Municipal Conflict of Interest Act (the
"MCIA") — while the Integrity Commissioner may provide general interpretation of the MCIA, it is
expected that individual members of Council or local boards will seek independent legal advice
on a specific question of individual compliance with such legislation.
Appendix 3
COMPLAINT PROTOCOL
(1) Any member of Council, staff or the public that believes they have
experienced or witnessed conduct in contravention with the Code of
Conduct may file a complaint and request an investigation.
(2) All complaints shall be in writing and signed by an identifiable
individual.
(3) A complaint shall set out reasonable and probable grounds for the
allegation that the member has contravened the Code of Conduct and
include a support affidavit that sets out the evidence in support of the
complaint.
(4) The complaint protocol information package shall be available at the
County Clerk's office.
Appendix 4
AFFIDAVIT
Code of Conduct Complaint Protocol — Formal Complaint Procedure
Please note that signing a false affidavit may expose you to prosecution under Sections 131 and 132
or 134 of the Criminal Code, R,S,C, 1985, c. C -46, and also to civil liability for defamation.
AFFIDAVIT OF
(full name)
(full name), of the (City, Town, etc.)
of (municipality of residence)
MAKE OATH AND SAY (OR AFFIRM):
1. I have personal knowledge of the facts as set out in this affidavit, because
in the Province of Ontario
(insert reasons e.g. I work for ..1 attended the meeting at which ..etc.).
2. I have reasonable and probable grounds to believe that a member of Elgin County Municipal Council,
(specify name of member), has contravened
section(s) (specify section(s)) of the Code of Conduct
for members of Council (the "Code of Conduct "). The particulars of which are as follows:
(Set out the statements of fact in consecutively numbered paragraphs in the space below, with each
paragraph being confined as far as possible to a particular statement of fact. If you require more space,
please use the attached Schedule A form and check the appropriate box below. If you wish to include
exhibits to support this complaint, please refer to the exhibits as Exhibit A, B, etc. and attach them to this
affidavit.)
Please see the attached Schedule A
1. This affidavit is made for the purpose of requesting that this matter be reviewed and for no
other purpose.
SWORN (or AFFIRMED) before me at
The Municipality of Central Elgin in the
County of Elgin in the Province of Ontario on
) (A Commissioner for taking affidavits. etc. - Signature)
)
)
) (Date)
)
)
) (Complainant Affidavit, - Signature)
)
)
) (Date)
Elgin
Appendix 4 (page 2)
AFFIDAVIT
Code of Conduct Complaint Protocol — Formal Complaint Procedure
Please note that signing a false affidavit may expose you to prosecution under Sections 131 and 132
or 134 of the Criminal Code, R,S,C, 1985, c. C-46, and also to civil liability for defamation.
Schedule A
To the affidavit required under subsection 2(3) of The Formal Complaint Procedure
(If more that one page if required, please photocopy this blank page and mark each additional page as 2
of 2, 2 of 3, etc. at the top right comer)
**Affidavit to be submitted with filing fee as prescribed by
County of Elgin Municipal Fees & Charges Schedule.
This is Schedule A referred to in the affidavit of
(full name)
Sworn (or Affirmed) before me on this
day of
A Commissioner for taking affidavits, etc.- Signature
Complainant Affidavit, - Signature
Complainant Affidavit, - Date of Submission
* Personal information B collected under the authority of Section 239 of The Municipal Act (as
amended) and will be used by The Integrity Commissioner to carry out an investigation under
the Act.