Outside employment guidelines

Guidance on managing Conflict of Interest (COI)

When NRC employees engage in outside employment that draws on their professional skills, they can face conflict of interest (COI) issues that not only have implications for their own credibility, but can also reflect upon the integrity of the organization as a whole.

It matters to all of NRC, and employees and prospective employees are thus required to make a declaration whenever considering activity as described below.

In this context, “outside employment” involves financial or other compensation for work that is not a function of an employee’s official NRC duties and can include acting as a consultant or owner of an incorporated business.

This document is meant to supplement the NRC Policy on Conflict of Interest and Post-Employment (COI-PE) (Annex B – Section 2.2). It also supports employees in meeting the terms and conditions of employment, the NRC Code of Conduct, the Values and Ethics Code for the Public Sector, Section 121 of the Criminal Code of Canada, and relevant Government of Canada policies.

Should you have any questions, comments, or suggestions on these guidelines, please do not hesitate to contact the NRC Secretary General’s Office at COI.NRC@nrc-cnrc.gc.ca

Who decides when a declaration is made?

NRC employees and prospective employees have the responsibility to declare whenever they consider engaging in outside employment that could be seen to involve the use of professional skills, contacts, or resources required in the course of their official NRC duties or that otherwise relate to NRC’s mandate.

Additionally, they are to provide such information when requested by their management or the NRC Secretary General’s Office.

What information to include in a Conflict of Interest (COI) form?

NRC employees are to make their COI declarations via the online form.

This declaration should include

  1. a list of NRC duties as well as relevant financial and staffing authorities;
  2. a description of the outside employment and the employer’s business interests; and
  3. input from the supervisor and CTE reviewing officer.

The Secretary General’s Office may also seek corroborating information through other means such as sources in the public domain and conversations with the relevant management.

When to submit a Conflict of Interest (COI) declaration?

NRC employees are to submit a declaration to the NRC Secretary General’s Office (NRC-SGO) whenever they consider engaging in outside employment that could be seen to involve the use of their professional skills, contacts, or resources required and developed in the course of their official NRC duties or that otherwise relate to NRC’s mandate.

Questions to ask yourself

  1. Could a reasonable third-party believe that you have special access to scientific, technical, commercial, client lists, or market information that could benefit your outside employment?
  2. Do you have supervisory responsibilities or access to equipment, information technology systems, or other resources at NRC or remotely that could benefit your outside employment?
  3. Could you influence colleagues, affect recommendations or take decisions in a way that could benefit your outside employment or have an impact on competitors of your outside employer?
  4. Do you interact with NRC clients or other stakeholders who also have interactions with your outside employer?
  5. Does your outside employment involve work of a high risk nature or matters of public concern?
  6. Does your outside employment involve possible contracts with NRC or receiving a benefit from NRC directly or indirectly through a family member and separate from your regular employment with NRC?
  7. Could any NRC business line provide this service or product?

Where do I submit the Conflict of Interest (COI) form?

The NRC Conflict of Interest Form can be submitted to the NRC Secretary General’s Office.

You can consult the NRC Secretary General’s Office about the process via COI.NRC@nrc-cnrc.gc.ca

How NRC might manage Conflict of Interest (COI) risks around outside employment

Before granting conflict of interest clearance for outside employment, NRC may take mitigating measures which will take into account any special authorities as well as supervisory or management responsibilities.

These measures could include:

  1. Employee to ensure that outside employment does not interfere with the normal conduct of NRC duties;
  2. Employee to not represent NRC in its business dealings with the outside employer or its competitors;
  3. Employee to not represent the firm or other entity in its dealings with NRC;
  4. Employee to not advertise services or solicit clients for outside businesses through business cards, brochures, or other materials while acting in an NRC capacity;
  5. Employee to not use an official title or relationship with NRC in business marketing materials or social media platforms;
  6. Employee to recuse his or herself from NRC discussions and decisions related to their outside employer and its competitors even if this means limiting their client base;
  7. Employee to inform others, internal or external parties, of the outside employment on a need-to-know basis as determined by management;
  8. Employee to not use NRC resources that could contain trade secrets or financial, commercial, scientific or technical information concerning the outside employer or its competitors;
  9. Employee to take steps to ensure that there is no appearance that work related to the outside employment is conducted with NRC equipment, systems, or resources;
  10. Employee to provide relevant information to their management for a trial period or on an ongoing basis; and
  11. Employee to terminate outside employment or take leave without pay.