The Commissioner’s advice was sought as to whether it would be appropriate for a class of senior public servants to attend a fundraising dinner as guests of a key government stakeholder or whether they should be required to pay the full price of a ticket. These senior public servants were likely to be regarded as key participants in the event, and it was to provide a valuable opportunity for dialogue and relationship-building.
The Commissioner was of the view that it would be inappropriate for the senior public servants in question to attend the function as guests of the stakeholder. It could be perceived that the key government stakeholder was providing the class of senior public servants with a gift, of greater than nominal value, in the hope of doing business with the Crown, and this would be contrary to section 4 (accepting gifts) of the regulation. A further issue was the fact that the event was a fundraiser and a portion of the ticket price would go to the stakeholder. The Commissioner’s advice was that public funds should not be used towards the fundraising efforts of a government stakeholder. In order to mitigate the risk of conflicts, the Commissioner suggested that, rather than purchase tickets at the full price, the public servants determine the per-person cost of the dinner, and each public servant pay only that portion of the price of a ticket. Thus, the public servants would neither attend at the expense of the stakeholder nor contribute to the fundraising. The public servants were advised to then request reimbursement for the paid portion in accordance with government directives that are in place for out-of-pocket expenditures. This procedure would ensure openness and transparency with regard to the expenditure of public funds.
O. Reg. 381/07, s. 4.