Good intentions do not shield against conflict of interest

  • October 20, 2022

The Protecteur du citoyen received a disclosure indicating that a senior manager of a public body allegedly was in conflict of interest in the context of a project requiring the use of livestock. He seemingly sold animals belonging to him to the public body which employed him, with the option of buying back the livestock. He had housed the animals on his property and could potentially benefit personally.

The Protecteur du citoyen decided to investigate to see whether wrongdoing had occurred. 


More than once, the manager acquired livestock for his employer. After being reimbursed for the first purchase, he signed sales contracts with his employer. Each contract designated him as the vendor of the animal. A clause provided that he could buy back the animal at the same price should his employer want to dispose of it.

For several months, the manager had housed on his premises animals belonging to the employer and had charged fees for boarding them.

The manager’s version

The manager says that he became financially and personally involved in order to minimise costs for the pilot project and ensure the welfare of the animals. By signing contracts with buyback options, he hoped to protect the animals—if they became useless to the project, he would keep them and take care of them properly.


The Protecteur du citoyen does not question the manager’s good intentions. However, he should have found some other way of proceeding which would have enabled him to comply with the rules. In acting as he did, he contravened:

The manager’s actions were consistent with a serious breach of codes of ethics and professional conduct.

They constituted wrongdoing under the Act to facilitate the disclosure of wrongdoings relating to public bodies


The Protecteur du citoyen recommended that the public body authorities:

The public body accepted the Protecteur du citoyen’s recommendations. It stated that a considerable portion of the recommendations had already been dealt with through the work underway.

The Protecteur du citoyen sees to the integrity of public services and is part of the action to improve them. Have you witnessed what you think was a wrongdoing  relating to a public body? Do you have information suggesting that such an act was committed or is about to be? Disclose now.