Office of the Conflict
of Interest and Ethics
Commissioner

Commissariat aux
conflits d’intérêts et à
l’éthique

Referral from the Public Sector Integrity Commissioner:
The Bonner Report

made under the

CONFLICT OF INTEREST ACT

February 26, 2015
Mary Dawson
Conflict of Interest and
Ethics Commissioner

 Referral from the Public Sector Integrity Commissioner:
The Bonner Report

made under the
CONFLICT OF INTEREST ACT

For additional copies of this publication, please contact:
Office of the Conflict of Interest and Ethics Commissioner
Parliament of Canada
66 Slater Street, 22nd Floor
Ottawa, Ontario K1A 0A6
Telephone: (613) 995-0721
Fax: (613) 995-7308
Email: ciec-ccie@parl.gc.ca
Ce document est également publié en français.
This publication is also available online at the following address:
http://ciec-ccie.parl.gc.ca

© Office of the Conflict of Interest and Ethics Commissioner, Parliament of Canada, 2015

022015-48E

 PREFACE
The Conflict of Interest Act, S.C. 2006, c. 9, s. 2 (Act) came into force on July 9, 2007.
An examination under the Act may be initiated at the request of a member of the Senate
or House of Commons pursuant to subsection 44(1) of the Act or on the initiative of the Conflict
of Interest and Ethics Commissioner (Commissioner) pursuant to subsection 45(1).
When an examination is initiated under section 45 of the Act, the Commissioner is
required, under subsection 45(3), to provide a report to the Prime Minister setting out the facts in
question as well as the Commissioner’s analysis and conclusions in relation to the examination,
unless the examination is discontinued. Subsection 45(4) provides that, at the same time that a
report is provided to the Prime Minister, a copy of the report is also to be provided to the public
office holder or former public office holder who is the subject of the report and made available to
the public.
On receipt of a referral from the Public Sector Integrity Commissioner pursuant to
subsection 24(2.1) of the Public Servants Disclosure Protection Act, the Commissioner may, if
she has reason to believe that a public office holder or former public office holder has
contravened the Act, decide to examine the matter on her own initiative pursuant to section 45 of
the Act.
Whether or not the Commissioner initiates an examination under section 45 of the Act,
the Commissioner must, pursuant to section 68 of the Act, provide a report to the Prime Minister
setting out the facts in question as well as her analysis and conclusions where there has been a
referral from the Public Sector Integrity Commissioner. A copy of the report must also be
provided to the public office holder or former public office holder who is the subject of the report
and to the Public Sector Integrity Commissioner. The report is also made public.

 TABLE OF CONTENTS
EXECUTIVE SUMMARY ......................................................................................................................... 1
CONCERNS ................................................................................................................................................ 3
First concern .............................................................................................................................................. 3
Second concern ......................................................................................................................................... 3
Third concern ............................................................................................................................................ 3
Fourth concern........................................................................................................................................... 4
PROCESS .................................................................................................................................................... 5
FINDINGS OF FACT ................................................................................................................................. 7
Background ............................................................................................................................................... 7
Invitation from Vale Canada Ltd............................................................................................................... 8
The National Arts Centre Gala .................................................................................................................. 8
Meeting of October 4, 2013 .................................................................................................................... 10
Payment for the National Arts Centre Gala............................................................................................. 11
Invitation from Aerospace Industries Association of Canada ................................................................. 11
Meeting of September 20, 2013 .............................................................................................................. 13
Annual Aerospace Reception and Dinner ............................................................................................... 13
Meeting of November 13, 2013 .............................................................................................................. 16
Payment for the Annual Aerospace Reception and Dinner ..................................................................... 16
Invitation from Forest Products Association of Canada.......................................................................... 16
Meeting of September 20, 2013 .............................................................................................................. 17
Annual Alumni Dinner of the Parliamentary Internship Programme...................................................... 18
Payment for the Annual Alumni Dinner ................................................................................................. 19
MR. BONNER’S POSITION ................................................................................................................... 21
ANALYSIS AND CONCLUSIONS ......................................................................................................... 23
Analysis ................................................................................................................................................... 23
Payment for the Invitations ..................................................................................................................... 28
Conclusion............................................................................................................................................... 28
OBSERVATIONS ..................................................................................................................................... 29
SCHEDULE: LIST OF WITNESSES ..................................................................................................... 31

 EXECUTIVE SUMMARY
This report presents the findings of my examination under the Conflict of Interest Act (Act)
of the conduct of Mr. Michael Bonner when he was a senior policy advisor in the Office of the
Minister of Employment and Social Development, in connection with event invitations that he
accepted in the fall of 2013.
In November 2013, I received a letter raising concerns about Mr. Bonner’s conduct as it
related to four possible contraventions of the Act. I subsequently received a referral about
Mr. Bonner from the Public Sector Integrity Commissioner pursuant to subsection 24(2.1) of the
Public Servants Disclosure Protection Act. The information in the referral was from the same
individual who had sent me the letter, it was almost identical to that contained in the letter, and it
covered the same concerns.
Only one concern warranted an examination under the Act, namely that Mr. Bonner had
contravened section 11, which prohibits a public office holder from accepting any gift that might
reasonably be seen to have been given to influence the public office holder in the exercise of an
official power, duty or function.
Mr. Bonner had accepted gifts consisting of an invitation from Vale Canada Ltd. to attend
the National Arts Centre Gala, an invitation from the Aerospace Industries Association of Canada
to attend the Annual Aerospace Reception and Dinner, and an invitation from the Forest Products
Association of Canada to attend the annual Alumni Dinner of the Parliamentary Internship
Programme. The federal Registry of Lobbyists shows that each of these organizations reported a
meeting with Mr. Bonner shortly before or after the events to which they had invited him.
I found that these organizations were all stakeholders of the Department of Human
Resources and Skills Development Canada (continued under the name Employment and Social
Development Canada) and were registered to lobby that department, particularly in areas related
to Mr. Bonner’s responsibilities as a senior policy advisor. This should have put him on notice
that the invitations might reasonably be seen to have been given to influence him in respect of his
official responsibilities. It should have been clear to Mr. Bonner that the invitations did not meet
the acceptability test set out in section 11 of the Act.
I therefore concluded that Mr. Bonner contravened section 11 of the Act by accepting the
invitations from Vale Canada Ltd., the Aerospace Industries Association of Canada and the
Forest Products Association of Canada.

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 CONCERNS
On November 10, 2013, I received an email containing an attached letter and supporting
documents from a member of the public regarding Mr. Michael Bonner, who was at that time a
senior policy advisor to the Honourable Jason Kenney, P.C., Minister of Employment and Social
Development 1.
The letter raised concerns relating to four possible contraventions of the Conflict of Interest
Act (Act).
On January 23, 2014, I received a referral from the Public Sector Integrity Commissioner
about Mr. Bonner as I was about to initiate an examination under the Act in relation to one of the
concerns raised in the November letter. The information in the referral was from the same
individual who had sent me the letter and the information was almost identical to that found in
the letter and covered the same concerns.
The discussions below address three of the concerns for the purposes of the Conflict of
Interest Act and at the same time fulfill the requirement under section 68 of the Act that I prepare
a report in response to the referral from the Public Sector Integrity Commissioner in relation to
those concerns. Only a fourth concern warranted an examination under the Act.
First concern
A first concern was that Mr. Bonner used a BlackBerry issued by the government for
non-government related purposes. This concern was not pursued because the activity identified
did not relate to any prohibition under the Act. This was a concern that would more appropriately
be dealt with by his employer.
Second concern
A second concern was based on speculation that was unsupported by any information and
was therefore not pursued.
Third concern
A third concern was that Mr. Bonner was engaging in outside employment and serving as a
paid consultant while he was a reporting public office holder. This concern required some

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On July 15, 2013, the Honourable Jason Kenney, P.C., was sworn in as Minister of Employment and Social
Development, but it was on December 12, 2013 when Bill C-4, the Economic Action Plan 2013 Act, No. 2, received
Royal Assent that the Department of Human Resources and Skills Development Canada (HRSDC) was continued
under the name Employment and Social Development Canada (ESDC).

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 preliminary research to determine whether I had reason to believe that Mr. Bonner had
contravened subsection 15(1) of the Act by engaging in prohibited outside activities.
My Office contacted Mr. Bonner on December 20, 2013 for his comments in response to this
concern. He stated that he was not employed or serving as a paid consultant outside of the
Minister’s office and that this third concern related to volunteer activities that he engaged in for
his academic studies. My Office contacted the organization identified in the letter in this regard
and the organization confirmed what Mr. Bonner had told my Office.
I was satisfied with the results of the research carried out by my Office. I concluded that
I had no reason to believe that Mr. Bonner had contravened subsection 15(1) of the Act and did
not pursue the matter further.
Fourth concern
The fourth concern was that in the fall of 2013, Mr. Bonner accepted gifts consisting of
invitations to galas and fundraisers from stakeholders of Human Resources and Skills
Development Canada, as it was then known, who have had or were likely to have official
dealings with the Minister’s office. It was alleged that these invitations had a value of $200 or
more and had not been declared by Mr. Bonner.
Three specific events were mentioned in this connection, two of which were scheduled for
the same evening. In response to this concern, Mr. Bonner confirmed with my Office that he had
accepted an invitation from Vale Canada Ltd. to attend the National Arts Centre Gala and an
invitation from the Aerospace Industries Association of Canada to attend its Annual Aerospace
Reception and Dinner.
Research conducted by my Office revealed that Mr. Bonner had attended a third event,
which had not been identified by the individual raising the concerns. Mr. Bonner confirmed that
he received an invitation from Forest Products Association of Canada to attend the annual
Alumni Dinner of the Parliamentary Internship Programme.
The federal Registry of Lobbyists showed that each of the three organizations whose events
Mr. Bonner attended had reported a meeting with him within a short time period either before or
after the events. This information gave me reason to believe that Mr. Bonner had contravened
subsection 11(1) of the Act, which prohibits a public office holder from accepting any gift that
might reasonably be seen to have been given to influence the public office holder in the exercise
of an official power, duty or function.
The remainder of the report addresses the fourth concern by way of an examination relating
to section 11 of the Act.
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 PROCESS
On February 3, 2014, I decided to launch an examination in accordance with
subsection 45(1) of the Conflict of Interest Act (Act), and I wrote to Mr. Michael Bonner to
inform him accordingly. I indicated that I had reason to believe he may have contravened
subsection 11(1) of the Act and I asked him to provide me, in writing, with any factual
information and documents related to my examination, as well as his views on whether or not he
had contravened any of his obligations under the Act in connection with the gifts described
above. I also asked him to respond to a series of questions about the invitations, the organizations
that sent the invitations and the events he had attended.
I also informed Mr. Bonner in my letter of February 3, 2014, that I had received a referral
from the Office of the Public Sector Integrity Commissioner, and I enclosed a copy of the
confidential disclosure, blocking out parts that would identify the individual who submitted the
disclosure.
I received a response from Mr. Bonner on March 3, 2014, and further information from his
lawyer, Mr. Paul Lepsoe, on March 7, 2014. There was then a series of email exchanges between
my Office and Mr. Lepsoe over several weeks to gather additional information. Mr. Bonner
explained that he could not provide me with any emails related to my examination because he
had deleted them, as his usual practice was to delete emails every two weeks. He added that
deleted emails of ministerial staff remain on the server for about four weeks, but are then lost
forever as they are not “archived”. A request to the Chief Information Officer for Mr. Bonner’s
emails was unsuccessful.
Two interviews were conducted with Mr. Bonner: the first on April 16, 2014, and the
second, after all other witnesses had testified and their submissions had been received, on
November 4, 2014. Before proceeding with the second interview, Mr. Bonner was given an
opportunity to review the transcript from his first interview, excerpts of transcripts from two
witness interviews and other relevant documents.
My Office interviewed three witnesses. Two of the witnesses and eight other individuals
submitted written statements and supporting documents.
In keeping with the practice I have established, Mr. Bonner and his counsel were given an
opportunity to comment on a draft of the factual sections of this report (Concerns, Process,
Findings of Fact and Mr. Bonner’s Position) before it was finalized.

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 FINDINGS OF FACT
Background
Mr. Michael Bonner was hired on February 4, 2013, as Senior Policy Advisor by the
Honourable Jason Kenney, P.C., who was then Minister of Citizenship, Immigration and
Multiculturalism. On July 15, 2013, Minister Kenney was appointed Minister of Employment
and Social Development, although the department officially remained under the name
Department of Human Resources and Skills Development Canada until December 12, 2013.
Mr. Bonner remained Senior Policy Advisor to Minister Kenney in his new ministerial position.
As a member of ministerial staff, Mr. Bonner was subject to the Conflict of Interest Act (Act) as a
reporting public office holder.
Mr. Bonner left his position on October 14, 2014, and is therefore subject to
post-employment rules under Part 3 of the Act.
It was alleged that Mr. Bonner contravened subsection 11(1) of the Act by accepting, in the
fall of 2013, complimentary invitations to social events that constituted gifts that might
reasonably be seen to have been given to influence him in the exercise of his official powers,
duties or functions.
In this report, because the period relevant to this examination was the fall of 2013, I will
refer to the department as the Department of Human Resources and Skills Development Canada
(HRSDC).
In making my determination, I considered Mr. Bonner’s official powers, duties and
functions, and the relationship and interactions between the organizations that gave him the
invitations and his official role. I also considered the mandate of HRSDC at that time.
According to its website, the legislative mandate of HRSDC included improving “the
standard of living and quality of life of all Canadians by promoting a highly skilled and mobile
labour force and an efficient and inclusive labour market.” In this regard, HRSDC offered
funding opportunities for individuals and businesses for a range of programs. Those relevant to
this examination include career development, skills training and employment.
Mr. Bonner told me that, as a senior policy advisor in Minister Kenney’s office, he was
responsible for various files including Aboriginal labour market programming, the Youth
Employment Strategy, Education (such as student loans) and the Temporary Foreign Workers
Program. He told me that he communicated any advice to the Minister through notes that he
would normally send directly to him.

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 Mr. Bonner said that his responsibilities included relations with stakeholders. He added that
his responsibilities include providing political advice with respect to programs. Mr. Bonner
informed me that he had met with 47 stakeholders between July and December 2013.
Invitation from Vale Canada Ltd.
Vale Canada Ltd. (Vale) is a mining company and according to its website, it operates,
among other projects, an open-pit mine at Voisey’s Bay, Labrador. In a letter to my Office dated
April 11, 2014, Mr. Kevin Inwood, Senior Associate General Counsel at Vale, explained that at
the beginning of the Voisey’s Bay operations in the 1990s, Vale entered into a partnership with
the surrounding Aboriginal communities and the Government of Canada to develop and
implement an Aboriginal workforce training program to operate the mine. According to
Mr. Inwood, the program, called the Joint Education and Training Authority, became a model for
future training initiatives in Canada.
The federal Registry of Lobbyists showed that, in the fall of 2013, Vale was registered to
lobby HRSDC, as well as a number of other federal departments in relation to several matters,
including “Aboriginal Training: Information on current skills and training programs and potential
synergies with Vale Inco Operations in Canada.”
Mr. Inwood wrote in his letter that Vale recently announced plans to develop an
underground mine, starting in 2019, at Voisey’s Bay when the open-pit mine will close. He
indicated that Vale had begun preliminary discussions with some federal departments on
workforce training since the training needed to operate an underground mine was different from
that for the currently operated open-pit mine, and that Vale hoped to establish a new partnership
with the Aboriginal communities and the federal government. Mr. Inwood also wrote that Vale
saw HRSDC as an important constituent in this initiative and hoped to build relationships in that
regard, and added the following conclusion: “hence the invitation to Mr. Bonner.”
Mr. Bonner told me that the Aboriginal labour market program was to expire on
March 31, 2015, and that it had been fully subscribed for many years. He added that part of the
Minister’s mandate was to evaluate the program and perhaps to renew it subject to Cabinet
decision. He said that, “as Policy Advisor, it was my job to provide political advice to the
Minister based on the recommendations of the department.”
The National Arts Centre Gala
Ms. Audrey Leduc, Vale’s Corporate Affairs Officer, sent an email to Mr. Bonner on
September 13, 2013, to officially invite him and a guest to the National Arts Centre (NAC) Gala
that would take place on September 21, 2013. The invitation mentioned the Vale mining project
at Voisey’s Bay, specifically stating that “this will be a great opportunity for our Vice President
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Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 of Corporate Affairs, Cory McPhee, to tell you a bit more about the ramping up [of] Phase 2 of
our Voisey’s Bay Project in northern Labrador.” In addition, the email invitation provided a few
details about the project, noting that training and skills development were priority areas in line
with federal resource development objectives. Mention was also made of an agreement with the
Innu and Inuit people.
On September 20, 2013, Ms. Leduc sent a follow-up email describing the evening’s program
to Mr. Bonner. The email mentioned that the evening was a black tie event and would begin with
cocktails, followed by a Gala concert featuring Paul Anka, and then dinner.
Mr. Bonner told me that before accepting the invitation, he had researched Vale. After
realizing that Vale was formerly known as Inco, he made the connection to Mr. McPhee because,
while working at Inco, Mr. McPhee was a client of Mr. Bonner’s previous employer,
Allan Bonner Communications Management Inc. Mr. Bonner had also been a partner in that
organization. In a letter to me, dated February 28, 2014,Mr. Bonner wrote that he assumed that he
was invited to the Gala because Mr. McPhee knew him. Neither the letter from Mr. Inwood nor
the email from Ms. Leduc, both of whom are referred to above, made any reference to a personal
connection.
During Mr. Bonner’s second interview on November 4, 2014, I asked him if the content of
the email invitation, particularly the reference to an opportunity for Mr. McPhee to brief him
about the Voisey’s Bay project, raised concerns about accepting the invitation. He said that it
hadn’t, partly because he recognized Cory McPhee’s name. Mr. Bonner also told me that, before
accepting the tickets, he had researched the event and found pictures of previous NAC Galas
attended by former and current parliamentarians, bureaucrats and other Canadian socialites and
officials. He said that the event itself looked like a normal part of the Ottawa scene, the type of
event that a parliamentarian, an assistant or a bureaucrat would normally attend.
The Gala was held at the NAC on September 21, 2013. Mr. Bonner attended with his guest
and was seated at the Vale table, which was hosted by Mr. McPhee. According to Mr. Bonner’s
testimony during his first interview, no mention was made of his duties or of Vale’s activities at
the Gala. Instead, talk included matters such as the city of Sudbury, the town of Naughton, books
and art.
In his letter to my Office, Mr. Inwood stated that, at the end of the evening, Mr. McPhee had
a short conversation with Mr. Bonner about Vale’s success in hiring Aboriginal people to build
the open-pit mine at Voisey’s Bay and the company’s desire to repeat this success with the
underground mine at Voisey’s Bay. According to Mr. Inwood, Mr. McPhee also told Mr. Bonner
that the company would follow-up with him or with the person in charge of the file in

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 Minister Kenney’s office. In his second interview, Mr. Bonner said that he did not remember the
Voisey’s Bay project being raised at the NAC Gala.
On September 30, 2013, Mr. John Mullally, Vale’s Corporate Affairs Director, emailed
Mr. Bonner, thanking him for attending the Gala on September 21, 2013, and requesting a
meeting with him to bring him up to speed on the success of the first phase of the Voisey’s Bay
mining site and on the planned expansion. That request was accompanied by a short explanatory
text on the Voisey’s Bay project and a statement that Vale will be looking to engage the federal
government on its new funding envelopes announced in Budget 2013. Mr. Bonner told me in his
first interview that he was not advised as to the purpose of the proposed meeting with Vale. In his
second interview, on being shown a copy of the email, Mr. Bonner said he vaguely recalled
receiving it, but did not recall replying to it.
Meeting of October 4, 2013
Mr. Michael Von Herff of Public Affairs Advisors, a lobbying firm engaged by Vale,
organized and attended a meeting held on October 4, 2013 with Mr. Bonner and two
representatives from Vale, Mr. Mullally and Mr. Bob Carter, Corporate Affairs Manager for
Newfoundland and Labrador. Public Affairs Advisors reported the meeting to the federal
Registry of Lobbyists listing the subject matter as Aboriginal affairs, mining, employment and
training. Vale also reported this meeting in the federal Registry of Lobbyists.
Vale informed my Office in writing, through Mr. Inwood, that it was logical that Mr. Bonner
be selected for the meeting because he was in charge of the Aboriginal workforce training file in
Minister Kenney’s office and the meeting was to be about the Voisey’s Bay project, which
included an Aboriginal workforce training component. Mr. Inwood wrote that during the meeting
the Joint Education and Training Authority (JETA) was discussed since “it had been over a
decade since JETA was implemented and [Vale] thought it worthwhile to re-establish a baseline
understanding of the program and its success, as the government looks at models for skills
training.”
Mr. Bonner testified that the meeting was not a lobbying activity. According to Mr. Bonner,
the meeting was introductory and the purpose of it was to learn about Vale’s activities in Canada.
Mr. Bonner said that he told Vale that he had no control over, nor involvement in, any dealings
they may have with the HRSDC department, and that he could and would do nothing for them.
In his letter to me dated February 28, 2014, Mr. Bonner wrote that “I do not take notes in
meetings with stakeholders.” He confirmed this statement when asked about it during his first
interview. When he was then asked whether he made notes after a meeting, he replied that he did
not. He later stated that he “made it through a doctorate without ever taking notes. It’s just not

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 something that I do.” When he was asked why some meetings were not inserted in his agenda,
Mr. Bonner said, “they just don’t always go in,” but he shows up at meetings because he
remembers them. When asked whether he had an extremely good memory, Mr. Bonner replied,
“I believe I do.”
Mr. Inwood said in his letter of April 11, 2014, that the presentation to Mr. Bonner was
similar to that made on March 25, 2014, by Vale’s Vice-President of Corporate Affairs,
Mr. McPhee, in his appearance before the Standing Committee on Human Resources, Skills and
Social Development and the Status of Persons with Disabilities. In that presentation, Mr. McPhee
talked about the proposed underground mining project at Voisey’s Bay and expressed Vale’s
desire that the past partnership in training the Aboriginal workforce be repeated for the future
underground mine.
Mr. Inwood stated in his letter that there had not been any further meetings with Mr. Bonner,
and Mr. Bonner told me that there were no requests made at the meeting or issues that needed
follow-up.
Payment for the National Arts Centre Gala
Vale is a corporate sponsor for the NAC Gala, a fundraising event in support of the
National Youth and Education Trust. As a result of its corporate sponsorship, Vale received
20 complementary tickets (two tables) to the Gala. The advertised price of a ticket to the Gala
was $1000 and it was understood that for those paying $1000 there would be a tax receipt for all
but the direct cost of the evening. Officials of the NAC advised my Office that the NAC sends
VIP invitations to select public office holders as NAC guests, offering a special ticket price of
$195, which reflects the direct cost of the evening.
In February 2014, shortly after this examination was launched, Mr. Bonner contacted Vale to
ask about the value of the tickets he had received to the Gala. He was directed to the NAC
Foundation and advised that the value of the tickets was $195 each, or $390 in total. Although he
was not on the VIP list, Mr. Bonner paid $390 to the NAC Foundation on February 7, 2014. NAC
officials advised my office that Mr. Bonner was not on the VIP list at the time of the Gala.
Invitation from Aerospace Industries Association of Canada
The Aerospace Industries Association of Canada (Aerospace Association) states on its
website that it is a “not-for-profit organization serving as an advocate on aerospace policy issues
that have a direct impact on aerospace companies and aerospace jobs in Canada”.
The federal Registry of Lobbyists shows that the Aerospace Association was registered in
the fall of 2013 to lobby a number of federal departments, including HRSDC.
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 The federal Registry of Lobbyists also shows that Ms. Maryse Harvey, Vice-President of
NATIONAL Public Relations Inc. (NPR), and Mr. Matthew Triemstra, Senior Consultant with
NPR, were registered in the fall of 2013 to lobby HRSDC, on behalf of the Aerospace
Association, from May 21, 2013 to January 14, 2014 and from July 18, 2013 to
December 13, 2013, respectively. The public registration indicated that they were registered to
lobby HRSDC in relation to employment and training, and that they were conducting outreach to
public office holders as it related to the implementation of the recommendations of the
Emerson Report.
The Emerson Report resulted from an arm’s length advisory committee mandated by the
Government of Canada in February 2012 to conduct a national aerospace review. The review was
led by the Honourable David Emerson, P.C. The purpose of the review was to produce
recommendations on how federal policies and programs can help maximize the competitiveness
of Canada’s aerospace and space sectors. The review resulted in a report published in
November 2012 entitled Beyond the Horizon: Canada’s Interest and Future in Aerospace, also
known as the Emerson Report.
During the review, six expert working groups were established to provide information and
advice on key issues relating to specific themes for the review. One of the working groups was
the People and Skills Working Group, chaired by Mr. Gregory Yeldon, a member of Aerospace
Association’s board of directors and President of Esterline CMC Electronics. Mr. Yeldon’s
working group published a report entitled Final Report of the People and Skills Working Group
on September 1, 2012, which was considered in the preparation of the Emerson Report.
According to Mr. Yeldon, not all of the recommendations of the People and Skills Working
Group were included in the Emerson Report, in particular a recommendation to hold a national
discussion forum consisting of stakeholders.
Following the publication of the Emerson Report, the Aerospace Association formed a Skills
Committee, chaired by Mr. Yeldon. The mandate of the Skills Committee, according to
Mr. Yeldon, included ensuring that the Emerson Report recommendations were implemented by
the Government and advocating for a national forum. Mr. Yeldon wanted to discuss the issue of
the national forum with HRSDC and Minister Kenney.
Mr. Chris Froggatt, Ottawa Managing Partner at NPR, confirmed in a written submission,
dated April 28, 2014, that the Aerospace Association had retained them as of late May 2013 and
that their mandate included overall government relations services in regard to the implementation
of the Emerson Report recommendations and assistance with the coordination of the
2013 Canadian Aerospace Summit, an annual event hosted by the Aerospace Association.
Mr. Froggatt wrote that this Summit, which includes a reception and dinner, is the main public
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 relations event for the Aerospace Association each year. He added that it was therefore important
to have representatives from relevant ministers’ offices attend.
Mr. Froggatt wrote that in 2013, NPR had identified Mr. Bonner, Senior Policy Advisor, and
Mr. Gerrit Nieuwoudt, then Deputy Chief of Staff and Director of Policy, as political staff
members relevant to the Aerospace Association because they were employed in the office of the
minister responsible for HRSDC. Mr. Froggatt added that the Emerson Report included a number
of recommendations related to the aerospace workforce that were important to the Aerospace
Association and on which the Aerospace Association wanted to follow-up with HRSDC to ensure
that they were implemented by the Government.
Meeting of September 20, 2013
On August 6, 2013, Mr. Bonner replied to an email he had received from Mr. Triemstra of
NPR, writing that he would be happy to meet with Mr. Jim Quick, Aerospace Association’s
President and CEO. Earlier that day Mr. Triemstra had sent an email to Mr. Nieuwoudt
requesting that he also meet with Mr. Quick, stating that the purpose of the meeting would be for
Mr. Quick to provide him with an overview of the aerospace industry as well as with an update
on the progress of the implementation of the Emerson Report recommendations, and the
involvement of HRSDC. This purpose was repeated in a subsequent email from Mr. Triemstra.
A meeting was arranged for September 20, 2013.
Documents provided to my Office by NPR show that, the day before the scheduled meeting,
NPR provided a briefing note to Mr. Quick on the meeting’s objectives. These included updating
Mr. Bonner and Mr. Nieuwoudt on the progress of the implementation of the Emerson Report
recommendations and seeing how they could help move forward recommendations related to
studies on aerospace workplace experience, government support for “up-skilling” and
government co-funding of infrastructure for aerospace training and research purposes. The note
also included an item that read: “Invite to attend the Aerospace dinner on October 16th, with
Chris Hadfield.”
Mr. Quick met with Mr. Nieuwoudt at the meeting of September 20, 2013. Mr. Bonner did
not attend the meeting. He told my Office that his reason for not attending was that he was
extremely busy at that time and added that he may not even have been invited. Mr. Bonner told
me that he had not discussed the meeting with Mr. Nieuwoudt.
Annual Aerospace Reception and Dinner
As part of the 2013 Canadian Aerospace Summit, an evening in honour of
Commander Chris Hadfield was held at the Ottawa Convention Centre on October 16, 2013 and
was organized by the Aerospace Association, with the help of NPR.
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 Mr. Froggatt of NPR wrote that NPR recommended to the Aerospace Association that
Mr. Bonner be invited as a guest of the Aerospace Association because Mr. Bonner was a
political staffer in the Office of the minister responsible for HRSDC, the federal department
relevant to and responsible for implementing the employment and skills development
recommendations made in the Emerson Report.
Mr. Bonner was invited to the October 16, 2013 dinner and reception at the end of
September 2013. The invitation stated that Mr. Bonner was invited by Mr. Quick, President and
Chief Executive Officer of the Aerospace Association.
Mr. Quick informed my Office that on the back of Mr. Bonner’s invitation there was a label
stating: “A nominal fee for food and beverage costs can be charged to public office holders to
ensure compliance with hospitality guidelines if required. To inquire about this, please contact
[. . .],” with an Aerospace Association representative’s phone number and email address provided
for the invitee to contact. Mr. Bonner did not recall having read the label nor did he recall having
contacted the Aerospace Association telephone number or email address provided on the label.
Mr. Quick wrote that before the event, there was no discussion between the Aerospace
Association and Mr. Bonner about payment of the nominal fee mentioned on the label
accompanying the invitation. He wrote that the nominal fee for the event was $70 plus HST.
After receiving the invitation, Mr. Bonner told me that he had conducted a web search on the
Aerospace Association. Mr. Bonner said that he made no link between the invitation and the
email request he had received from Mr. Triemstra on August 6th, 2014 to meet with Mr. Quick of
the Aerospace Association.
When I asked Mr. Bonner whether he had some responsibility for the Emerson Report file,
Mr. Bonner replied that he did not know what the Emerson Report was, adding that he had never
read it. When asked whether he would consider the Aerospace Association a stakeholder of
HRSDC, Mr. Bonner replied only that there is no Canadian person or company that is not a
stakeholder of HRSDC.
On October 8, 2013 Mr. Triemstra of NPR sent an email to Mr. Bonner and Mr. Nieuwoudt
to follow-up on the invitation to the Aerospace Association dinner on October 16. The email
stated that each of them with a guest were invited to attend the dinner “as our guests”. In his
response letter, Mr. Bonner confirmed that when he accepted the invitiation, he knew that
Mr. Trimestra was inviting him on behalf of the Aerospace Association. Mr. Nieuwoudt did not
attend.

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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 At the request of Ms. Harvey of NPR, Mr. Bonner was seated at a table purchased by
Mr. Greg Yeldon, an Aerospace Association board member chairing the Aerospace Association’s
Skills Committee. Mr. Yeldon told my Office during an interview that Mr. Bonner was seated at
his table because Mr. Bonner was with HRSDC and the Aerospace Association wanted
Mr. Yeldon to explain to Mr. Bonner the importance of having the Emerson Report
recommendations related to employment and skills development implemented by HRSDC.
Mr. Yeldon told my Office that during the dinner he told Mr. Bonner about his role with the
Aerospace Association, especially his role chairing the People and Skills Working Group. He
stated he was sure they had discussed generally the Aerospace Association’s priorities and the
recommendations made in the Emerson Report and the People and Skills Working Group Report
and that he had suggested a follow-up meeting with Mr. Bonner to discuss the reports in greater
detail. Mr. Yeldon also told my Office that during the dinner, Mr. Bonner offered to set up a
meeting between the Aerospace Association and Minister Kenney.
In an email dated October 21, 2013, Mr. Yeldon wrote that, as he and Mr. Bonner had
discussed, he was providing Mr. Bonner with Internet links to access the Emerson Report and the
People and Skills Working Group Report. He also stated in the email that he appreciated
Mr. Bonner’s offer to arrange a meeting between the Aerospace Association and
Minister Kenney and proceeded to request a meeting with Mr. Bonner as well to review the
recommendations in the two reports, set out the Aerospace Association’s priorities, get feedback
from Mr. Bonner and discuss next steps before briefing the Minister.
In his reply to Mr. Yeldon’s October 21, 2013 email, Mr. Bonner wrote that he enjoyed their
chat and stated that they should meet as soon as they could, and copied the Minister’s scheduling
assistant to set up a meeting between himself and Mr. Yeldon.
During his first interview, Mr. Bonner told me that he did not know who was at his table and
was unaware of who purchased it, although he said that no Aerospace Association member was at
his table. He stated that to the best of his knowledge, there was no discussion about HRSDC’s
mandate or about the Aerospace Association. Mr. Bonner added that, to the best of his
recollection, the discussion concerned Mr. Bonner’s background in Byzantine and Iranian history
and languages.
Mr. Yeldon testified that he was at the table and that he told Mr. Bonner during the dinner
about his role with the Aerospace Association and discussed the Aerospace Association’s
priorities relating to the report of the People and Skills Working Group and the Emerson Report.
When Mr. Yeldon’s testimony was presented to Mr. Bonner during his second interview,
Mr. Bonner said at first that he had no recollection of any such discussion or any similar

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 discussion. However, later in the same interview, he said that Mr. Yeldon may have mentioned
some elements of the content of the reports or alluded to what they deal with at the dinner.
During his second interview, Mr. Bonner denied offering to arrange a meeting between the
Aerospace Association and the Minister, adding that it does not fall within his power to do so.
Meeting of November 13, 2013
A meeting was held on November 13, 2013, between Mr. Bonner and Mr. Yeldon.
Ms. Lucie Boily, Vice President, Policy and Competitiveness of the Aerospace Association, also
attended the meeting. The Aerospace Association reported the meeting in the federal Registry of
Lobbyists, setting out the subject matter of the communication as employment and training.
Mr. Yeldon told my Office that he had discussed the Emerson Report and the People and
Skills Working Group report recommendations in detail with Mr. Bonner at this meeting, as well
as the Aerospace Association’s priorities from a public policy perspective.
Mr. Bonner did not recall discussing either of the reports with Mr. Yeldon on November 13.
He told me that he told the Aerospace Association representatives that he had no control over, or
involvement with, any dealings that they may have with the HRSDC department, and that he
could and would do nothing for them.
There were no further meetings between Mr. Bonner and the Aerospace Association.
Payment for the Annual Aerospace Reception and Dinner
Mr. Yeldon informed my Office that the cost of the table was $1,650 for 10 seats, or $165
per person plus tax.
On February 4, 2014, Mr. Bonner contacted Mr. Triemstra at NPR to find out the value of
the ticket for the October 16, 2013 dinner and was informed that the value of the ticket was $170,
but that the government rate was $70.
On February 6, 2014, Mr. Bonner paid the Aerospace Association $70 plus tax.
Invitation from Forest Products Association of Canada
According to its website, the Forest Products Association of Canada (Forest Products)
describes itself as “ the voice of Canada’s wood, pulp and paper producers nationally and
internationally in government, trade and environmental affairs.” Forest Products advocates on the
forest industry’s behalf and is registered to lobby the federal government on a number of subject
matters, including labour, employment and training.
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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 In the fall of 2013, the federal Registry of Lobbyists shows that Forest Products was
registered to lobby HRSDC, and a number of other federal departments in support of matters
relating to the “forest sector’s current and future employment needs. (e.g. EI, Immigration,
Mobility, Skilled Trades, Accreditation Policy, Labour Market Information, Apprenticeship,
Canada Job Grant).”
Meeting of September 20, 2013
In his written response to our request for information, Mr. David Lindsay, President and
CEO of Forest Products, wrote that Forest Products was seeking to establish a contact with
HRSDC following the Cabinet shuffle of July 15, 2013. He mentioned that
Ms. Francesca Iacurto, Forest Product’s Director of Government and External Relations, sent an
email to Minister Kenney’s office on September 9, 2013, stating that she was:
[. . .] looking to make contact with someone in your office for the purpose of ‘meeting
and greeting’ – i.e., simply providing an overview of our sector, and discussing if/how
FPAC can help assist the Minister carry out his priorities generally.
A meeting was scheduled for Ms. Iacurto for September 20, 2013 with Mr. Robert Larocque,
Director, Environment and Labour Market Policies at Forest Products, along with one of
Mr. Bonner’s colleagues. Although Forest Products was not aware that Mr. Bonner would be
attending, Mr. Bonner was also present at the meeting.
Forest Products reported this meeting in the federal Registry of Lobbyists. Mr. Bonner said
that, at the meeting, the discussion centred on logging, cutting down trees for the pulp and paper
industry, the number of employees, training, and Aboriginal peoples. Mr. Bonner told me that the
purpose of the meeting was to get to know one another. He also indicated that he had told Forest
Products that he had neither control over, nor involvement in, any dealings that they may have
with the HRSDC department. He told me that he said that he could and would do nothing for
them.
According to Ms. Iacurto’s notes of that meeting, Forest Products had discussed the
“greenest workforce” (an online forest products industry resource and recruitment tool), as well
as employment insurance, temporary foreign workers, and data on Forest Product’s area of the
Canadian economy. The notes also indicated that they had discussed an invitation that
Mr. Lindsay had sent, on behalf of Forest Products, to Minister Kenney on August 22, 2013, in
which he invited the Minister to attend Forest Product’s board meeting in December 2013.
The invitation letter to Minister Kenney identified “a shortage of labour, especially in the
skilled trades” as a critical challenge for the forest products industry. It stated, “[. . .] our Board
would appreciate the opportunity to have a personal dialogue with you to discuss these issues
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 further, and explore additional ways of partnering with government to address our current and
future recruiting challenges.”
According to Ms. Iacurto’s notes of the meeting, Mr. Bonner and his colleague were given a
copy of the invitation to the Minister, the invitation was discussed and “they [Mr. Bonner and his
colleague] seemed interested”. During his second interview, Mr. Bonner was asked whether he
could tell us anything about Forest Product’s invitation to the Minister and Ms. Iacurto’s note
indicating that he and his colleague “seemed interested”. Mr. Bonner replied, “I have no control
of or interest in the Minister’s schedule. I don’t know if this meeting took place or when it took
place and I don’t know for what purpose”. Mr. Bonner said that he did not recall receiving a copy
of the invitation in question and that he did not know whether Ms. Iacurto followed up with
anyone in the Minister’s office about the invitation.
Annual Alumni Dinner of the Parliamentary Internship Programme
The 2013 annual Alumni Dinner of the Parliamentary Internship Programme, a fundraising
event, was held on November 5, 2013. This event was an evening in honour of the
Right Honourable Kim Campbell, P.C.
Mr. Lindsay mentioned that, as a sponsor of the Parliamentary Internship Programme, Forest
Products had reserved a table for eight people at a cost of $125 per person. He wrote that, as the
date approached, Forest Products looked to fill its seats and invited Mr. Bonner since they
thought he may have been interested because of his political background and because he was
from an age group similar to that of the parliamentary interns.
My Office asked Forest Products for a copy of the email invitation to Mr. Bonner.
Ms. Iacurto replied that they did not have a copy, but that it would have included a short
description of the event and the related logistical information. She added that Mr. Bonner’s
assistant confirmed his presence by telephone.
In his second interview, I asked Mr. Bonner whether he had concerns about accepting the
invitation, given that he had met with Forest Products on September 20, 2013. He said he did not.
Mr. Bonner attended the event and was seated at a table with Mr. Lindsay, Ms. Iacurto and
Mr. Larocque. Mr. Bonner told me that during the evening, there was no discussion relating to his
work or to Forest Products’ interests. He said they talked about Canadian history, particularly the
Northwest Rebellion of 1885, and Guy Fawkes Day, which happened to be that day. Mr. Lindsay
stated in his letter that no discussions relating to Mr. Bonner’s responsibilities took place that
evening. Mr. Bonner, Mr. Lindsay and Ms. Iacurto all confirmed that there were no follow-up or
further meetings between Forest Products and Mr. Bonner.

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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 Payment for the Annual Alumni Dinner
Mr. Bonner telephoned Ms. Iacurto on February 4, 2014 to ask about the price of his ticket to
the Alumni Dinner of the Parliamentary Internship Programme. Ms. Iacurto confirmed in an
email that the cost was $125. Mr. Bonner paid Forest Products $125 on February 6, 2014.

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Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 MR. BONNER’S POSITION
Mr. Bonner’s position is that he did not contravene section 11 of the Conflict of Interest Act
(Act).
In his response letter of February 28, 2014, Mr. Bonner said that he did not believe there had
been any impropriety whatsoever. None of the three organizations that had given him invitations
had made any requests of him. He wrote that the invitations were to standard annual Ottawa
social events and that it was commonplace that guests, including public office holders, be invited
to attend. He said that the price of the tickets to each event was less than $200.
Mr. Bonner noted that, when he was hired by Minister Kenney, he was new to Ottawa and
only recently returned to Canada after a very long absence abroad and “with a wide mandate to
conduct outside liaison on behalf of the Minister’s office.” He wrote that the events in question
were all part of the “Ottawa Scene” and appeared to him to be the type that he should be
attending in terms of the outreach he was supposed to be doing.
Mr. Bonner suggested that it was possible that the organizations that had invited him wanted
to enhance their public image by being seen as contributing to the success of the events in
question because they had public office holders at their table, but that did not mean that they
should be seen as trying to influence him.
Mr. Bonner wrote that he assumed he was invited to the National Arts Centre Gala by
Mr. Cory McPhee of Vale Canada Ltd., because he had some previous acquaintance with
Mr. McPhee, who had been a client of Allan Bonner Communications Management Inc. where
Mr. Bonner had worked before becoming a public office holder.
He also noted that the scope of his department’s mandate is so vast that practically everyone
in Canada is affected by one of its programs. Therefore, according to Mr. Bonner, “it cannot be
the case that any hospitality, however modest, offered to anyone associated in any way with
HRSDC might reasonably be seen to be given to influence that person, within the meaning of
section 11 of the Act”.
With respect to his meetings with officials from Vale, the Aerospace Association and the
Forest Products Association, Mr. Bonner wrote that these officials wished to make contact with
him, the new Senior Policy Advisor in the new Minister’s office following the cabinet shuffle, to
get acquainted. He wrote that at the beginning of each meeting each stakeholder said that the
purpose of the meeting was essentially social and “to get to know me”.

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Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

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 He wrote that he then told them all the same thing: that he had no control of, nor
involvement in, any dealings which they may have with the department, and that he could and
would do nothing for them. Mr. Bonner wrote that in his view, none of the meetings constituted
lobbying per se in that he was not asked to do anything on a particular bill, contract or policy,
etc., and that none of the three organizations had made any requests of him.
Mr. Bonner is also of the view that the exception of the Act should apply to the invitations,
and believes they are a “normal expression of courtesy or protocol, or are within the customary
standards that normally accompany the public office holder’s position.” Mr. Bonner argued that
this exception applies given that these events are such a regular part of the annual “Ottawa
scene”, and that inviting public office holders is not only standard for the events but likely crucial
to their success.
Mr. Bonner noted in his letter that, without any acknowledgement of impropriety in
accepting the invitations, he had since paid for the costs of the dinner tickets himself. He stated
that he had paid $195 each for 2 tickets to the NAC Gala, $70 plus tax for a ticket to the Annual
Aerospace Reception and Dinner and $125 for a ticket to the Parliamentary Internship Dinner.

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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 ANALYSIS AND CONCLUSIONS
Analysis
It is alleged that Mr. Bonner contravened section 11 of the Conflict of Interest Act (Act) by
accepting the following invitations:
•
•
•

an invitation from Vale Canada Ltd. to the National Arts Centre Gala;
an invitation from the Aerospace Industries Association of Canada to its Annual
Aerospace Reception and Dinner; or
an invitation from Forest Products Association of Canada to the annual Alumni
Dinner of the Parliamentary Internship Programme.

The relevant portions of section 11 read as follows:
11. (1) No public office holder or member of his or her family shall accept any gift or
other advantage, including from a trust, that might reasonably be seen to have been
given to influence the public office holder in the exercise of an official power, duty or
function.
(2) Despite subsection (1), a public office holder or member of his or her family
may accept a gift or other advantage
(a) that is permitted under the Canada Elections Act;
(b) that is given by a relative or friend; or
(c) that is received as a normal expression of courtesy or protocol, or is
within the customary standards that normally accompany the public
office holder’s position.
I must determine whether a reasonable person with knowledge of the relevant facts would
conclude that the invitations had been given to influence Mr. Bonner in respect of an official
power, duty or function.
If I conclude that an invitation was unacceptable under subsection 11(1) of the Act, then
I must determine whether the exception in paragraph 11(2)(c) applies with respect to that
invitation, that is whether it was received as a normal expression of courtesy or protocol, or was
within the customary standards that normally accompany the public office holder’s position.

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Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

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 I will consider each of the invitations separately.
Invitation from Vale to the National Arts Centre Gala
When Vale offered Mr. Bonner tickets to the NAC Gala in September 2013, Vale was
registered in the federal Registry of Lobbyists to lobby the Department of Human Resources and
Skills Development Canada (HRSDC) in respect of several matters, including “Aboriginal
Training: Information on current skills and training programs and potential synergies with
Vale Inco Operations in Canada”.
Mr. Bonner told me that he was responsible for Aboriginal labour market programming in
Minister Kenney’s office. He was involved in the evaluation of the program and decisions on
whether it should be renewed. In addition, one of Mr. Bonner’s responsibilities was to liaise with
stakeholders. At the time the invitation was extended, it was reasonable to assume that
Mr. Bonner would be involved in meetings with Vale or participating in policy discussions in the
Minister’s office relating to Vale and its Voisey’s Bay project. Vale officials did in fact meet with
Mr. Bonner to discuss the Voisey’s Bay project and the Aboriginal workforce training component
on October 4, 2013.
The mere fact that Vale was a stakeholder of HRSDC and was registered to lobby the
department, particularly in relation to Aboriginal training, should in itself have put Mr. Bonner
on notice that the invitation from Vale might reasonably be seen to have been given to influence
him, as Senior Policy Advisor with regard to the Aboriginal labour market programming file.
Mr. Inwood, Senior Associate General Counsel at Vale, was very forthcoming as to why
Vale offered the invitations to Mr. Bonner. He stated in his letter to my Office that Mr. Bonner
was invited because Vale saw HRSDC as an important constituent with regard to a new
partnership that Vale wanted to build with the Aboriginal community and the federal government
for its new mining project in Voisey’s Bay. He wrote that Vale had begun discussions with
federal departments on workforce training requirements for the new project.
In fact, the email invitation dated September 13, 2013 to Mr. Bonner stated that during the
Gala, Vale’s Vice-President of Corporate Affairs, Mr. McPhee, would want to tell Mr. Bonner
about Vale’s new Voisey’s Bay project in northern Labrador and that skills and training were an
important area of focus. The invitation referred to agreements with the Innu and the Inuit people.
I find that the invitation “might reasonably be seen to have been given to influence”
Mr. Bonner in respect of his official responsibilities and he should not have accepted it.

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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 It is interesting to note, as well, that Mr. Inwood wrote to my Office that Mr. McPhee did, in
fact, have a short discussion with Mr. Bonner about the project at the end of the Gala evening and
said he would follow-up with a meeting with Mr. Bonner.
As for the exception in paragraph 11(2)(c) for a gift that is received as a normal expression
of courtesy or protocol, or is within the customary standards that normally accompany the public
office holder’s position, I am satisfied that it does not apply. My Guideline on Gifts (including
Invitations, Fundraisers and Business Lunches), published in July 2011, states that the Office
considers a normal expression of “courtesy or protocol” to be a token expression of appreciation
in the context of some official interaction. An example would be a token thank you gift following
an appearance, speech or presentation.
Nor do I consider the invitation to be within the customary standards that normally
accompany Mr. Bonner’s position as Senior Policy Advisor in Minister Kenney’s office. My
guideline on gifts states that what is considered to be within the “customary standards” of a
position depends on the circumstances. In this guideline, I gave the example of a gift given by an
official from a foreign or international organization who is visiting a public office holder as a gift
that would normally be covered by this exception.
Therefore, I find that Mr. Bonner contravened section 11 of the Act by accepting the
invitation from Vale to attend the National Arts Centre Gala.
Invitation from the Aerospace Industries Association of Canada to Its Annual Aerospace
Reception and Dinner
In September 2013, when Mr. Quick, President of Aerospace Industries Association of
Canada (Aerospace Association), invited Mr. Bonner to the Annual Aerospace Reception and
Dinner, the Aerospace Association was registered to lobby HRSDC. Before accepting the
invitation, Mr. Bonner was aware that the Aerospace Association was a stakeholder of HRSDC.
This information was sufficient to put him on notice, as in the case of Vale, that the officials of
the Aerospace Association might well be trying to influence him.
In August 2013, Mr. Bonner had agreed to meet with Mr. Quick who wanted to provide him
with an update on the progress of the implementation of the Emerson Report recommendations.
The Emerson Report was prepared by an external advisory committee following a review in
which Mr. Yeldon, a director of the Aerospace Association, had been involved.
On October 8, 2013, a week before the event, Mr. Bonner and Mr. Nieuwoudt, then Deputy
Chief of Staff and Director of Policy, received an email from Mr. Triemstra from National Public
Relations, advising that they should have received invitations to the event. In the email,

Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

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 Mr. Triemstra asked if Mr. Bonner would be interested in attending the event as the guest of
NPR. Mr. Triemstra was one of the lobbyists at NPR registered to lobby HRSDC on behalf of the
AIAC in respect of employment and training and was conducting outreach to public office
holders as it related to the implementation of the Emerson Report. It was also Mr. Triemstra who
emailed Mr. Bonner twice in August 2013 requesting that a meeting be arranged with Mr. Quick
to discuss the Emerson Report. Mr. Bonner should certainly have realized then that the invitation
might be part of a government relations strategy developed by NPR for the Aerospace
Association and that it was related to his duties as a senior policy advisor.
Mr. Bonner told me that, before accepting the invitation, he had researched the Aerospace
Association’s website but made no connection with the earlier meeting request. I do not find
Mr. Bonner’s evidence in this regard to be credible, particularly in light of the short duration of
time between when he agreed to meet with Mr. Quick and when he received the invitation. Upon
receiving the invitation, Mr. Bonner should again have been put on notice that the Aerospace
Association wanted to cultivate a relationship with him in order to advance its interests in
connection with the Emerson Report.
In my opinion, it should have been clear to Mr. Bonner that the invitation “might reasonably
be seen to have been given to influence” him in the performance of his official duties and
functions.
In fact, Mr. Yeldon discussed the Emerson Report and the report of the People and Skills
Working Group with Mr. Bonner at the dinner and requested a follow-up meeting with
Mr. Bonner, which took place on November 13, 2013.
In my view, the exception in paragraph 11(2)(c) for a gift that is received as a normal
expression of courtesy or protocol, or is within the customary standards that normally accompany
the public office holder’s position, does not apply for the reasons set out above in relation to the
invitation from Vale.
Mr. Bonner should not have accepted the invitation to the Annual Aerospace Reception and
Dinner from the Aerospace Association. For these reasons, I find that Mr. Bonner contravened
section 11 of the Act in doing so.
Invitation from Forest Products Association of Canada to the Annual Alumni Dinner of the
Parliamentary Internship Programme
In the fall of 2013, when Forest Products Association of Canada (Forest Products) invited
Mr. Bonner to the annual Alumni Dinner of the Parliamentary Internship Programme, Forest
Products was a stakeholder of HRSDC and was registered in the federal Registry of Lobbyists to

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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 lobby HRSDC in respect of several matters, including the “forest sector’s current and future
employment needs (e.g. EI, Immigration, Mobility, Skilled Trades, Accreditation Policy, Labour
Market Information, Apprenticeship, Canada Job Grant).”
As in the cases of Vale and the Aerospace Association, this should have been sufficient to
put Mr. Bonner on notice that Forest Products might well have been seeking to influence him.
Before receiving this invitation, Mr. Bonner and a colleague in the Minister’s office had met
on September 20, 2013 with Ms. Iacurto, Forest Products’s Director, Government and External
Relations, and Mr. Larocque, Director, Environment and Labour Market Policies. At the meeting,
several matters within HRSDC’s mandate were discussed. Forest Products' officials shared with
Mr. Bonner a letter that had been sent to Minister Kenney inviting him to attend a Forest
Products directors’ meeting to discuss a shortage of labour in the forestry industry, particularly
skilled trades and a current partnership with Minister Kenney’s department for a recruitment
campaign.
Unlike the cases of Vale and the Aerospace Association, there was a reasonable possibility
that, as Mr. Lindsay, President and CEO of Forest Products, has testified, Forest Products had no
other motivation than to fill seats at the event and had invited Mr. Bonner because of his age and
political background. However Forest Products’ motivation for inviting Mr. Bonner was neither
communicated to nor known by Mr. Bonner at the time he considered and accepted the invitation.
Furthermore, the motivation of Forest Products in inviting Mr. Bonner is not relevant in
determining whether it could reasonably be seen that the invitation was given to influence
Mr. Bonner.
It is my view that given that Forest Products was a stakeholder and was registered to lobby
HRSDC in respect of federal employment matters, and that its officials had met with Mr. Bonner
on September 20, 2013 to discuss matters relating to HRSDC’s mandate, this should have been
enough to put Mr. Bonner on notice that the invitation “might reasonably be seen to have been
given to influence” him in the performance of his official duties and functions.
In my opinion, the exception in paragraph 11(2)(c) for a gift that is received as a normal
expression of courtesy or protocol, or is within the customary standards that normally accompany
the public office holder’s position, does not apply for the same reasons set out above in my
analysis of the invitation from Vale to the National Arts Centre Gala.
For these reasons, Mr. Bonner should not have accepted the invitation and in accepting it, he
contravened section 11 of the Act.

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Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

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 Payment for the Invitations
As set out in the Findings of Fact, Mr. Bonner quickly made payments for these three events
after he received my letter dated February 3, 2014, informing him that I was launching this
examination.
I note that public office holders are encouraged to contact my Office for confidential advice
before accepting gifts or other advantages. In some instances, public office holders contact my
Office after receiving a gift or other advantage. Where it is determined that such gifts or other
advantages are not acceptable under the test in subsection 11(1) and are not covered by the
exceptions in subsection 11(2), I have allowed the public office holders to return the gift to its
donor. Where a return is impossible given the nature of the gift, I have allowed the public office
holder to pay the donor the fair market value of the gift. I have taken this approach as a general
rule in order to encourage individuals to consult my Office about the acceptability of gifts.
The case of Mr. Bonner is very different. In the present matter, Mr. Bonner did not contact
my Office for advice to ensure his compliance with his obligation under the Act when he
received the invitations and attended the events. He did not make the payments for the invitations
until shortly after he received my letter of February 3, 2014, advising him that I was launching
this examination.
Conclusion
I have determined that all three invitations, the first from Vale to the National Arts Centre
Gala, the second from the Aerospace Association to its Annual Aerospace Reception and Dinner,
and the third from Forest Products to the Alumni Dinner of the Parliamentary Internship
Programme, constituted a gift or other advantage accepted by Mr. Bonner that could reasonably
be seen to have been given to influence him in the exercise of an official power, duty or function.
I have also determined that the exceptions in paragraph 11(2)(c) do not apply in relation to
these invitations.
Therefore, I find that Mr. Bonner contravened section 11 of the Act by accepting the
invitations in each case examined in this report.

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Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 OBSERVATIONS
Although this case deals with one public office holder and a specific set of circumstances,
there are more general observations to be made. The report will, hopefully, serve as a reminder to
all public office holders of their obligations with respect to the acceptance and disclosure of gifts
and other advantages.
The Conflict of Interest Act clearly states that public office holders must not accept any gift
or advantage that might reasonably be seen to have been given to influence them in the exercise
of an official power, duty or function.
I often hear from individuals subject to the regimes that I administer that they cannot be
swayed by gifts or other advantages given to them in the course of their duties. That may be the
case, and I believe in most instances that it may well be so. However, that is not the issue.
The test is not whether the donor intended to influence the recipient, nor whether that
recipient was indeed influenced. The test is whether a reasonable person might reasonably think
that the gift or other advantage was given to influence the individual receiving the gift.
To provide greater clarity on this issue, I have published on my website a guideline on gifts
that explains the gift rules in greater detail. I strongly urge public office holders to consult the
guideline, to exercise caution in the area of gifts, and above all to seek advice from my Office in
determining whether to accept any gift.

Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

29

 30

Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

 SCHEDULE: LIST OF WITNESSES
Except where noted, the names of all witnesses are listed below according to the organizations to
which they belonged at the time of the events that are the subject of this examination.
Interviews
Aerospace Industries Association of Canada
• Mr. Gregory Yeldon, Director
Employment and Social Development Canada
• Ms. Krista Wilcox
The member of the public who brought the concerns to our attention
Written submissions
Vale Canada Ltd.
• Mr. Kevin Inwood, Senior Associate General Counsel
Aerospace Industries Association of Canada
• Mr. Jim Quick, President and CEO
• Mr. Gregory Yeldon, Director
Forest Products Association of Canada
• Mr. David Lindsay, President and CEO
• Ms. Francesca Iacurto, Director of Government and External Relations
NATIONAL Public Relations Inc.
• Mr. Chris Froggatt, Managing Partner, Ottawa office
National Arts Centre
• Ms. Rosemary Thompson, Director of Communications and Public Affairs
Employment and Social Development Canada
• Mr. Charles Nixon, Chief Information Officer
Office of the Minister of Employment and Social Development
• Mr. Gerrit Nieuwoudt, Acting Chief of Staff

Office of the Conflict of Interest and Ethics Commissioner
Referral from the PSIC: The Bonner Report, made under the Conflict of Interest Act

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