Integrity Commissioner

The Integrity Commissioner is an independent and impartial position reporting directly to Council.  The Integrity Commissioner is responsible for oversight of the Code of Conduct for Members of Council, Committees and Local Boards and includes providing advice, issuing interpretations and reports, investigating complaints and where necessary, recommending sanctions.  The Integrity Commissioner is also responsible for providing educational programs to members of Council and staff.  

Municipal government can be complex, and Council, Committee and Local Board members can turn to the Integrity Commissioner to provide confidential advice on ensuring they maintain the high standards expressed in the Code of Conduct. The Integrity Commissioner investigates complaints about breaches to the Code of Conduct by members of Council, Committees and/or Local Boards.  The IC can summon evidence and witnesses under oath to complete an investigation. The Integrity Commissioner also provides opinions and reports to Council, Committees and Local Boards on issues of ethics and integrity. The Integrity Commissioner is also responsible to review requests for investigations regarding whether a meeting of Council, Local Board or Committee was properly closed to the public.  

Code of Conduct - Complaint Procedure

Any person who has reasonable grounds to believe that a Member (Council, Committee or Local Board member) has breached the code of conduct may proceed with a complaint and request an investigation.  Complaints must be submitted within ninety (90) days after the alleged violation occurred or the alleged violation came to the attention of the complainant.  No complaint may be filed under any circumstances where the alleged violation occurred more than six (6) months prior to the complaint being filed.  

Informal Complaints

Informal Complaints can be addressed by any person who believes that the activity of a Member has breached the Code of Conduct or the Municipal Conflict of Interest Act, but the person does not want to initiate a formal complaint. Any person may:

  • Advise the Member that his or her behaviour or activity appears to constitute a contravention;
  • Encourage the Member to acknowledge and agree to stop the prohibited behaviour or activity and avoid future occurrences of the prohibited behaviour or activity;
  • Where the Member agrees to cease the behaviour, confirm in writing that the agreement is satisfactory;
  • Where the Member's response is not satisfactory, 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 below.

Individuals are encouraged to pursue the informal complaint procedure as the first means of remedying behaviour or an activity that they believe violates the Code of Conduct or the Municipal Conflict of Interest Act.

Formal Complaint Procedure

Any individual who identifies or witnesses behaviour or an activity by a Member that they believe is in contravention of this Code of Conduct or the Municipal Conflict of Interest Act, may file a formal complaint.  

Any person may file a complaint with the Municipality by submitting in writing the prescribed Complaint Form to the Clerk.  The form must contain an attestation from the complainant that they believe that the facts as set out in the complaint are true to the best of their knowledge and belief and that they make those statements as if they were under oath.

Every complaint must be accompanied by the prescribed fee in the amount of $150.00.  

In the event the Integrity Commissioner determines that a complaint is frivolous, vexatious or does not disclose a breach of this Code of Conduct or the Municipal Conflict of Interest Act, at any point after the submission of the complaint, the complainant shall forfeit the fee.  If the result of the complaint is a negotiated resolution or a finding that the Member breached this Code of Conduct or the Municipal Conflict of Interest Act, the fee shall be refunded in part, up to 50%, based on the recommendation of the Integrity Commissioner.

Every complaint shall include the following:

  • The complaint must set out reasonable and probable grounds for the allegation that the Member has contravened this Code of Conduct or the Municipal Conflict of Interest Act.
  • Any witnesses in support of the allegation must be identified in the complaint.
  • The Integrity Commissioner may request additional information from the complainant prior to making an assessment.

The complaint shall be filed with the Clerk, who shall forward the matter to the Integrity Commissioner.  The Clerk shall also provide notice to Council by way of confidential internal communication that a complaint has been filed, but no details of the complaint shall be provided other than the fact of a complaint and whether it is a complaint under this Code of Conduct, the Municipal Conflict of Interest Act, or other policy has been received.

If the complaint is not, on its face, a complaint with respect to non-compliance with this Code of Conduct or the Municipal Conflict of Interest Act or the complaint is covered by other legislation or complaint procedure under another policy, the Integrity Commissioner shall refer the complaint to the appropriate entity for investigation, advise the complainant in writing, suspend the investigation until the matter has been finally disposed of, and report the suspension of the investigation to Council.

If the Integrity Commissioner is of the opinion that the referral of a matter to him or her is frivolous, vexatious or not made in good faith, or that there are no grounds or insufficient grounds for an investigation, the Integrity Commissioner shall not conduct an investigation and, where this becomes apparent in the course of an investigation, shall terminate the investigation.  The Integrity Commissioner shall communicate this position in writing to the complainant and the Member identified in the complaint.

Submitting a Complaint

Complaints, comments and concerns can be submitted online. Complaints are tracked and the staff will follow up with individual complaints. You can also download a complaint form and submit it to the Office of the Chief Administrative Officer and Town Clerk. All complaints must be signed. Anonymous complaints will not be received by the Clerk's Department or the Integrity Commissioner. 

Complaint forms are also available at Town Hall. Please email info@renfrew.ca or call 613-432-4848 to request a copy.