Aides to former Prime Minister Stephen Harper and other cabinet ministers led the list of officials found guilty of failing to file reports under Canada’s Conflict of Interest Act over the past six years, according to a new study.

Moreover, the proportion of ministers or ministerial staff fined for not respecting the Conflict of Interest Act has risen steadily since 2012, accounting for 60 per cent of cases flagged by the ethics commissioner so far this year, according to data accumulated by law firm Fasken Martineau.

Overall, the number of officials who failed to file the requisite reports increased after the Conservatives formed a majority government, reaching a high of 16 officials fined in 2013.

While the study found that more than half the ethics scofflaws between 2009 and 2015 worked in ministerial offices, the PMO or were ministers, officials at the Immigration and Refugee Board (IRB) led the list of agencies — singlehandedly accounting for 20.6 per cent of the violation notices published on Ethics Commissioner Mary Dawson’s website.

Guy Giorno, a lawyer at Fasken Martineau, a former chief of staff to Harper and author of the study, says the statistics send a message to hundreds of people about to be hired or appointed by the incoming Liberal government.

“For those who are in public office, I think it is a wake-up call to be more alert,” said Giorno, pointing out that it’s not very difficult to comply with the reporting rules.

Giorno said the failure to file ethics reports should be one of the factors taken into consideration when the government decides whether to reappoint someone to a position, although it doesn’t seem to have been a factor during the period studied.

“It should be taken into account, obviously, but it’s not, or it hasn’t been historically.”

Under Canada’s Conflict of Interest Act, more than 1,000 public office holders are required to file confidential reports to the ethics commissioner’s office outlining things like their assets, liabilities and outside interests. They are also supposed to update them if there is a significant change such as a material change in assets.

The numbers analyzed by Fasken Martineau show that between 2009 and 2015, on average one official per month has been fined for failing to file a report. Since 2009, the ethics commissioner has published 68 notices of violations, affecting 65 individuals. Three individuals were found to have violated the filing rules twice – cabinet minister Peter MacKay, who received two fines of $200 in 2009 and 2011, as well as IRB officials Robert Allan Markovits (who was fined $100 and $150) and Joanne Sajtos, who received a $300 fine in 2012 and $450 fine in 2014 – the highest imposed during the period studied.

The analysis by Fasken Martineau found the most common violation was failing to file a report concerning a material change in assets, which accounted for 41 notices and more than 60 per cent of cases.

The second most common violation was failing to submit a confidential report within 60 days of appointment.

While the average of all fines was $125, the analysis found 55 of the 68 fines were for $100.

So far this year, 10 people have been fined between January and October, including former Conservative cabinet minister Gary Goodyear, who was fined $100 in October for failing to disclose a material change related to his liabilities within 30 days.

Giorno said public office holders and the public alike should pay more attention to who is complying with the rules and who is not.

“I thought it was something that would bring home to people who are involved the fact that there is enforcement, there are consequences.”

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