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Conflict of Interest Policy

Conflict of interest

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About the policy


A Conflict of Interest policy exists to protect the interests of both the organization and its employees by providing a measure by which conflict of interest situations can be gauged. The revised policy, and this site, provide examples of conflicts of interest situations that you could encounter. However, we didn’t think of every situation. If you have questions, or feel you may be in a conflict of interest, talk to your exempt supervisor, manager, Director, General Manager or Labour Relations or HR Business Partner for support.​

There are six sections within this policy:​

Outside interests

The City encourages its employees to undertake responsibilities of service and citizenship in their communities, but not to use City time or resources for these activities without the prior agreement of their exempt supervisor.

Example of conflict: A City employee volunteers their time to coordinate a community sports program and uses a City photocopy machine to make copies of team lists for the coaches and parents.

Gifts, hospitality and other benefits

Many City employees interact with consultants, vendors, industry organizations and other external contacts regularly. This can result in a third party sending an employee a gift, paying for meals, or offering them invitations to social events. Accepting such offers can be considered a conflict of interest.  Employees need to understand when they can or cannot accept benefits offered to them because they work for The City of Calgary. 

Example of conflict: A management consultant who has done a lot of work with your area invites you for dinner and a hockey game and you accept the invitation. 

Furthering private interests

As an employee of The City of Calgary, you cannot use your position to further your personal interests or those of the people in your private life. 

Example of conflict: A friend asks you to put in a good word for their daughter who is seeking a job at The City.

Using City assets

We use tools and resources given to us at The City to perform our roles and do not share them or use them in a different way unless we have permission to do so. This is consistent to the terms set out in the Acceptable Use of City Technology Resources Policy. 

Example of conflict: An employee uses work tools from work at home to complete some yard work.

Using confidential information

Employees are entrusted with information and data needed to perform their jobs. This can be sensitive, confidential or merely associated with The City. This information cannot be shared with anyone outside of The City without permission. 

Example of conflict: You learn through work where a Calgary Flames player lives. You are tempted to share this information with a friend who considers this player a hero so they can drive past their home.

Political activity

Employees can be politically active, however, this must occur on personal time outside of the workplace. An employee who is running for office should not identify themselves as a City of Calgary employees in campaign materials. 

Example of conflict: You are a candidate in an election and list your specific accomplishments at The City in your campaign materials.

Questions about this policy?

Speak to exempt leaders in one of the following:

  • your exempt supervisor, Director or General Manager
  • City Auditor's Office
  • Corporate Security
  • Law - Legal Services
  • HR Business Partner
  • Labour Relations, Human Resources

Policy download


Download the full policy.

Frequently asked questions


1. What is the Conflict of Interest Policy?

The City’s Conflict of Interest Policy is a resource for employees and leaders to help identify when a conflict of interest may arise and how it should be addressed.​​

2. Why did the Conflict of Interest Policy need to be changed?

City employees are expected to perform their roles in a way that sustains citizen trust and confidence. As such, we need clear guidelines so employees know what they can, and cannot, do to comply with the policy and protect our collective reputation. In addition to clarifying expectations, the policy now spells out the people and business areas that can be contacted for support. When implemented, the revised policy will better protect The City’s reputation and that of its employees.

3. How did Labour Relations decide on the changes?

Representatives from Labour Relations engaged with multiple stakeholders across the organization, conducted best practice reviews within the broader public sector and updated the policy to be consistent with changing legislation. It then sought advice and approval from ALT.

4. What kinds of behaviour does the Conflict of Interest cover?

The Conflict of Interest Policy has six sections: 

  • Political Activity 
  • Using Confidential Information 
  • Using City Assets 
  • Gifts, Hospitality and other Benefits 
  • Outside Interests 
  • Furthering Private Interests

5. When will the new policy come into effect?

June, 1, 2019.

6. Does this revised Conflict of Interest Policy apply to Council or the staff in Council’s offices?

No. The policy applies only to individuals who are employed by The City of Calgary, including those on contract.

7. Is it possible to go further than what the policy prescribes in terms of disclosure and limitations on social engagements?

Yes. Some Business Units may determine that they need more stringent measures. Management within the business unit will be responsible for communicating any measures specific to their business to relevant staff.

8. What are the big changes that employees need to know?

While many aspects of the policy have been amended, the most substantive changes may be experienced by employees who work with external business associates. The following lists the changes we believe are most relevant to employees:

  • It has long been acceptable for a City employee to accept hospitality from business associates external to The City but this has changed. A City employee can no longer be hosted by a business associate in most circumstances. Hosted activities include meals, invitations to sporting or social events or attendance at conferences.
  • If an employee incurs expenses as a result of this change in policy (i.e. paying for their own meal and those of other City employees who attend a luncheon meeting with a business associate), they will be reimbursed in accordance with the Reimbursement of Employee Business Expenses Policy.
  • Employees can no longer accept gift cards from people outside of The City. A gift card given by one City employee to another, as a form of recognition for example, continues to be acceptable.
  • Employees can accept small gifts valued under $25 such as a box of chocolates, cookies or token promotional item from a member of the public or a business associate.
  • It has been clarified that an employee cannot participate in, or influence, human resources decisions such as hiring, compensation, performance evaluation with someone with whom they have a family or personal relationship.

9. What are the big changes that leaders need to know?

  • In addition to making new employees aware of this policy at the time of their hire, there is a new expectation that leaders check in with their employees regularly to ensure their circumstances have not changed in a way that means a conflict of interest might now arise.
  • If their Business Unit has any additional requirements over and above the Conflict of Interest Policy, they need to ensure their employees know about them.
  • If they can’t effectively respond to a question or issue raised by an employee, the leader should seek guidance from their leader, HR Business Partner or Labour Relations.
  • Leaders must document the actions and/or decisions they have made in response to requests from employees related to the Conflict of Interest Policy. A template will be made available through Human Resources for such documentation, or the leader may choose to use their own method to record the actions taken. The important point is that a record must be kept in the employee’s personal file that reflects what was discussed, and agreed upon, to address a conflict of interest issue.
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10. If someone has a question about what is now included in the Conflict of Interest Policy, what should they do?

Employees with questions can also ask their exempt Supervisor, Director or General Manager, the City Auditor’s Office, Corporate Security, Law – Legal Services, their HR Business Partner or Labour Relations in Human Resources.​

11. As a leader I’m supposed to document the actions and decisions I have made related to the Conflict of Interest policy, where should this document be filed?

This document should go on the employee’s HR file. That way, if the leader leaves or retires and their file is destroyed, we’ll still have record of what was discussed. You can use the template under the Resource page​ on this site or create your own documentation.​​

Policy resources