Government policy

Each public agency that is subject to the Alberta Public Agencies Governance Act (APAGA) is required to have a code of conduct (code) for its members and employees, as well as a process for administering this code. These agencies must also make their code available to the public, once it has been approved by the Ethics Commissioner.

This requirement also applies to subsidiaries of APAGA agencies, where the agency has majority control.

Changes to the Conflicts of Interest Act

In December 2017, amendments to the Conflicts of Interest Act (COIA) were proclaimed, bringing APAGA agencies and applicable subsidiaries under COIA requirements.

See conflicts of interest legislation changes.

Each APAGA agency has until April 30, 2018 to submit an updated code of conduct, for review and approval by the Ethics Commissioner. These codes must include:

  • specific elements identified in the COIA, including restrictions on gifts and limitations on concurrent employment
  • information about when the code becomes applicable to each person or category of people who are subject to it

The Ethics Commissioner will review all agencies’ codes of conduct to ensure compliance with the Act, and report back to the responsible minister and agency CEO or Chair by March 31, 2019.

Codes of conduct that have been approved by the Ethics Commissioner must be published by April 30, 2019. Public agencies must set out a notice period, indicating when the code of conduct will be implemented.

In the meantime, all public agencies are required to abide by their current code of conduct, which should continue to be publicly available until the new code has been approved by the Ethics Commissioner and published.

The Public Agencies Governance Framework (PDF, 300 KB) still applies to all APAGA public agencies and applicable subsidiaries, and requires that all directors be screened for potential conflicts of interest prior to their appointment. During the screening process, it is important that every real or potential conflict of interest be identified to determine whether the conflict can be adequately managed.

Section 10 of the framework states that:

  • all public agencies will have a code of conduct
  • the code will cover issues addressed in the Code of Conduct and Ethics for the Alberta Public Service, conflict of interest disclosure practices and safe disclosure practices.

The framework also requires that each public agency have a process for administering its code. The updated requirements and content for codes of conduct under the Conflicts of Interest Act are contained in section 23.922 of the Act.


A code of conduct is an important document, setting the tone and direction for ethical behaviour. It reflects a commitment to the agency’s values and provides a framework to guide ethical conduct in a way that supports the best interests of the agency and the public it serves. As a code cannot cover every ethical dilemma, the spirit and intent of the code should convey an overall expectation of ethical behaviour.

Making the code publicly available is required under the Conflicts of Interest Act. This requirement promotes transparency and accountability, and signals a commitment to ethical conduct.