Ethics Complaint Document Portfolio Eng

HOUSE OF COMMONS
CHAMBRE DES COMMUNES

CANADA
MARTHA HALL FINDLAY

MEMBER OF PARLIAMENT / DÉPUTÉE
WILLOWDALE
October 27, 2009
BY HAND AND BY FAX
Mary Dawson, Conflict of Interest and Ethics Commissioner Office

Office of the Conflict of Interest and Ethics Commissioner
Parliament of Canada
Centre Block, P.O. Box 16
Ottawa, Ontario
K1A 0A6
Dear Ms. Dawson,
We write to you today to express our concern about the conflicts of interest highlighted by the
publicly funded and partisan advertising and communications campaign promoting the
budgetary economic programs of the Government of Canada (the “Campaign”). We believe
that the heavily partisan nature of certain elements of the Campaign contravene both the
Conflict of Interest Code for Members of the House of Commons and the Conflict of Interest Act.
We wrote a letter to the members of the Treasury Board on October 9, 2009 expressing these
concerns (attached hereto for your review as Appendix 1). We have alleged that the overall
partisan nature of the publicly-funded Campaign and of certain specific elements thereof, is in
breach of:
1. The Government of Canada’s own communication policies including the Treasury
Board Communications Policy (“TBCP”) and the Federal Identity Program Policy
(“FIP”) under the Financial Administration Act;
2. Conflict of Interest Code for Members of the House of Commons (the “Code”);
3. Conflict of Interest Act (the “Act”); and
4. The political party financing provisions of the Canada Elections Act.
We have not received a response from the Treasury Board.

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We will be filing separate complaints with regard to the breaches of TBCP and FIP, as well as the
Canada Elections Act, with the appropriate authorities.
Please accept this letter and the enclosed appendices and attachments as our request for you
to:
1. Undertake the necessary inquiries of the Members of Parliament (each an “MP”, and
together “MPs”) identified herein as contravening the Code, and recommend
appropriate sanctions for each such contravening MP; and,
2. Undertake the necessary examinations of certain Public Office Holders, as defined by
the Act, listed herein, and assess the appropriate penalties for each such contravening
Public Office Holder.
THE COMPLAINT
The specific breaches are described below, organized according to communications medium.
Overall, the complaint is based on the fact that, in its taxpayer-paid advertising, events,
publications, web-sites and other assets, the Government of Canada has used, and is using
colours, images, slogans, “look and feel” aspects and other branding elements that are the
same as, or mirror those, of the Conservative Party of Canada (“Conservative Branding”). Some
of this activity (for example, use of symbols or slogans) contravenes the TBCP and FIP. The MPs
and Public Office Holders responsible for the Conservative Branding of the Campaign have used
public funds to promote the electoral prospects of the Conservative Party. The problem is
exacerbated when said advertisements, publications, web-sites and other assets are used, not
to provide information that is actually needed by Canadian citizens, but rather to extol the
virtues of the Government of Canada itself. In many cases we see unsubstantiated, false and/or
exaggerated claims of accomplishment. It is unfortunate enough that the Government of
Canada is wasting millions of taxpayer dollars on unnecessary advertisements, but this
complaint deals specifically with the conflict of interest demonstrated in the fact that these
self-congratulatory advertisements are replete with Conservative Branding, and that, as such,
these advertisements use taxpayer money to confer a direct benefit upon the Conservative
Party.

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CONFLICT OF INTEREST OF CODE FOR MEMBERS OF THE HOUSE OF COMMONS
Violations of the Code
The Code: The principles governing the Code hold that MPs must “fulfill their public duties with
honesty and uphold the highest standards so as to avoid real or apparent conflicts of interest”
(section 2), and the provisions of the Code hold that:
i. When performing parliamentary duties and functions, a(n) [MP] shall not act in
any way to further his or her private interests or those of a member of the
*MP’s+ family, or to improperly further another person’s or entity's private
interests. (section 8);
ii. A(n) [MP] shall not use his or her position as a(n) [MP] to influence a decision of
another person so as to further the *MP’s+ private interests or those of a
member of his or her family, or to improperly further another person’s or
entity's private interests. (section 9).
The Contravention: The Conservative Branding found in the Campaign, as well as the overall
partisan nature of the Campaign, promotes the private interests of the Conservative Party, a
private entity for the purposes of the Code and an entity to which all of the MPs in Government
are related. Accordingly, in using their positions to influence the content of the Campaign to
benefit the Conservative Party and in acting to ensure that the Campaign promotes the
interests of the Conservative Party, the MPs involved in the conception, approval and
dissemination of the Campaign and its elements have directly contravened Section 8 and 9 of
the Code. In doing so, the MPs involved in the conception, approval and dissemination of the
Campaign have also failed to uphold the “highest standards” associated with their public duties.
The Contravening MPs: The following MPs have acted in direct contravention of the Code by
virtue of their role in the conception, approval and dissemination of partisanized Campaign
materials. Accordingly, these MPs should be the subjects inquiries under the Code:
The Prime Minister and his Parliamentary Secretary,
The President of the Treasury Board and his Parliamentary Secretary,
The Minister of Finance and his Parliamentary Secretary,
The Minister of Public Works and Government Services and his Parliamentary Secretary,
The Minister of Transport, Infrastructure and Communities and his Parliamentary Secretary,
The Minister of Human Resources and Skills Development and her Parliamentary Secretary,
The Minister of Industry and his Parliamentary Secretary,

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The Minister of Natural Resources and her Parliamentary Secretary, and

The Minister of National Revenue and his Parliamentary Secretary.
THE CONFLICT OF INTEREST ACT
Violations of the Act
The Act: The Act applies the provisions of the Code to all Public Office Holders and holds that:
i. Every Public Office Holder shall arrange his or her private affairs in
a manner that will prevent the Public Office Holder from being in
a conflict of interest (section 5);
ii. No Public Office Holder shall make a decision or participate in
making a decision related to the exercise of an official power, duty
or function if the Public Office Holder knows or reasonably should
know that, in the making of the decision, he or she would be in a
conflict of interest (section 6(1));
iii. No Public Office Holder shall, in the exercise of an official power,
duty or function, give preferential treatment to any person or
organization based on the identity of the person or organization
that represents the first-mentioned person or organization
(section 7); and
iv. No Public Office Holder shall use his or her position as a Public
Office Holder to seek to influence a decision of another person so
as to further the Public Office Holder’s private interests or those
of the Public Office Holder’s relatives or friends or to improperly
further another person’s private interests. (Section 9).
The Contravention: As established above, the partisan nature of the Campaign serves to
promote the private interests of the Conservative Party, a “person” for the purposes of the Act
and an organization to which the relevant Public Office Holders, as identified below, belong.
The Public Office Holders used their office to benefit the Conservative Party by condoning,
approving, and allowing, the inclusion of Conservative Branding in the Campaign. Specifically,
by using their positions as Public Office Holders to influence the content of the Campaign for
the benefit of the Conservative Party, and in acting to ensure that the Campaign promotes the
interests of the Conservative Party, the Public Office Holders involved in the conception,
approval and dissemination of the Campaign and its elements will have directly contravened

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sections 6(1), 7 and 9 of the Act. By contravening sections 6(1), 7 and 9, these Public Office
Holders will have also contravened section 5 by failing to arrange their respective affairs to
prevent the subject conflicts of interest.
The Contravening Public Office Holders: The following Public Office Holders were involved in
the conception, approval and dissemination of the Campaign and have, in doing so, failed to
uphold the high standards associated with their public duties. Accordingly, these Public Office
Holders should be the subjects of examinations under the Act:
The Prime Minister, his Parliamentary Secretary and their ministerial staff;
The President of the Treasury Board, his Parliamentary Secretary and their ministerial staff;
The Minister of Finance, his Parliamentary Secretary and their ministerial staff;
The Minister of Public Works and Government Services, his Parliamentary Secretary and their
ministerial staff;
The Minister of Transport, Infrastructure and Communities, his Parliamentary Secretary and
their staff;
The Minister of Human Resources and Skills Development, her Parliamentary Secretary and
their ministerial staff;
The Minister of Industry, his Parliamentary Secretary and their ministerial staff;
The Minister of Natural Resources, her Parliamentary Secretary and their ministerial staff; and
The Minister of National Revenue, his Parliamentary Secretary and their ministerial staff.
CONSERVATIVE BRANDING IN THE CAMPAIGN
The various aspects of the Campaign, taken together, clearly demonstrate the conferring of a
significant benefit upon the Conservative Party. We have noted, and provided in the
appendices hereto, examples of taxpayer-paid advertising, events, publications, web-sites and
other tools using colours, images, slogans, “look and feel” aspects and other branding elements
that are the same as, or mirror those, of the Conservative Party of Canada (“Conservative
Branding”). Below is a description of Conservative Branding in different elements of the
Campaign as found in different media. We note, also, that the inappropriate partisan branding
efforts of the Conservative Party extend beyond just the material in the Campaign. This fact is
evidenced by the comparison in item 1 of Appendix 6, which indicates that the Conservative
Party platform for the 2008 federal election and the Speech from the Throne following that
election (and prepared by the Government of Canada) were identically branded.

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Television and Radio: Television advertisements are subject to the TBCP and the FIP.
Television advertisements under the Campaign have been transcribed and included for review
in Appendix 2. These advertisements use among other elements, (i) Conservative Party blue as
the dominant colour and (ii) Conservative slogans and tag lines, such as “stay the course” and
“we can’t stop now” (the partisan nature of these slogans is demonstrated by their central use
in Conservative Party funded communications, some of which have also been attached hereto
in Appendix 6). Taken together these aspects serve to benefit only the future electoral
prospects of the Conservative Party and do not promote awareness of non-partisan
Government of Canada initiatives in the way that publicly funded advertising campaigns should.
The radio advertisements also transcribed and included in Appendix 2 repeat partisan slogans
and refer Canadians to Conservative Branded websites like actionplan.gc.ca. These radio
advertisements reinforce the Conservative Branding contained in other parts of the Campaign,
including the television advertisements. We note that even those radio and television
advertisements transcribed and included in Appendix 4, which do not, on their own, contravene
laws or policies, still contribute to Conservative Branding by referring the public to seek more
information about initiatives on Conservative Branded websites like actionplan.gc.ca.
Print and Online Communications: Print and online communications are subject the TBCP and
the FIP. Examples of Government of Canada Campaign advertisements appearing in print and
online can be found in Appendix 3. The use, in these advertisements, of (i) campaign style
photographs, (ii) Conservative Party blue and (iii) Conservative Party slogans and tag lines such
as “stay the course” and “we can’t stop now” are examples of Conservative Branding and are in
direct violation of TBCP and FIP. Further, the print and online advertisements do not promote
awareness of Government initiatives as Government advertising should. The advertisements in
Appendix 3 contain in many cases unsubstantiated, false and/or exaggerated claims of
accomplishment. For example, the notion, as included in the communications tools attached
hereto in items 1 and 2 of Appendix 3, that the Government of Canada has “implemented 90%”
of its budgetary economic programs is misleading (as suggested by the October report of the
Parliamentary Budget Officer), and the idea that the Government of Canada is “creating jobs”,
as claimed in the communications tools attached hereto in 11 and 12 of Appendix 3, have not
been supported by any data linking job creation to budgetary economic programs.
Websites and Weblinks: Websites like actionplan.gc.ca and plandaction.gc.ca are subject to
the TBCP and FIP. These websites are unmistakably partisan in the same way that print, online,
television, and radio advertisements used in the Campaign are partisan. In fact, as
demonstrated in Appendices 4 and 6, a comparison of these websites with the Conservative

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Party’s own conservative.ca, demonstrates that these websites have been modeled after and
duplicate essential features of the partisan conservative.ca. The Conservative Branding
elements used in actionplan.gc.ca and plandaction.gc.ca include (i) election campaign style
photographs, (ii) overuse of Conservative Party blue and other partisan colour schemes, (iii) use
of partisan slogans and taglines, and (iv) links to personal or Conservative Party websites.
While funded as part of the Campaign by Government of Canada ostensibly to keep Canadians
abreast of the implementation of budgetary economic programs, these websites actually
include unmistakably partisan aspects including weblinks to the personal web and social media
pages of the Prime Minister. Appendix 4 includes screenshots of the contravening websites and
the partisan and/or personal websites they link to. Appendix 6 includes a direct comparison of
some of the most obvious aspects of conservative.ca that are duplicated directly in
actionplan.gc.ca. The conclusion must be that the aim, and the effect, of these websites and
the Conservative Branding aspects of the Campaign are to promote the electoral prospects of
the Conservative Party. One of the inappropriate links from actionplan.gc.ca is to the Prime
Minister’s personal YouTube page with a video of the Prime Minister playing the piano at the
National Arts Centre (something that can in no way be seen to contribute to raising awareness
of non-partisan budgetary economic programs).
Official Letters and References to the “Harper Government”: In addition to the Conservative
Branding of Government of Canada advertisements and websites, letters and direct
communications tools used by Public Office Holders also exhibit hallmarks of Conservative
Branding. These letters and direct communications are subject to, and in violation of, the TBCP
and FIP. A particular example of the Conservative Branding in such a letter is included in
Appendix 5. This letter was sent by the Minister of Natural Resources to participants in a
budgetary economic program. The letter is branded with an inappropriate (and unapproved)
campaign style picture of the Minister with an unapproved advertisement style citation for a
non-governmental agency (Couvrette, Ottawa), a direct reference to the Conservative Branded
actionplan.gc.ca, and other aspects contributing to the look and feel of a document implying
that the Conservative Party is synonymous with the Government of Canada.
Also included in Appendix 5 are screenshots of both Government websites and Google searches
of Government websites indicating the prevalent and inappropriate use of “The Harper
Government” in official Government communications. The Google search results indicate an
ever growing number of official Government materials violating the TBCP and FIP by foregoing
references to the "Government of Canada” in favor of the inappropriate and unapproved
“Harper Government”.

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Funding announcements and ‘novelty’ cheques: MPs have partisanized the delivery of funds to
their ridings by using Conservative Branding on novelty cheques to publicize funding
announcements under budgetary economic programs. The use of these cheques and other
tools with Conservative Branding improperly equates the Government of Canada and the
Conservative Party. The goal of equating the Conservative Party to the Government of Canada
is to give the impression that the Conservative Party is, or the individual Conservative Party MPs
announcing spending are, actually responsible for the Government of Canada’s many large
spending announcements instead of the Government of Canada itself. The announced funding
is NOT being provided by either the individual MP or the Conservative Party. This money has
come from Canadian taxpayers and must be provided in an impartial, non-partisan way. The
novelty cheques include actual names and signatures of the announcing MPs, the Conservative
Party logo, and/or additional elements implying partisan involvement in the funding process.
These elements result in the novelty cheques violating the TBCP and the FIP. Although this
partisan use of novelty cheques forms part of the Campaign to which this letter relates,
separate complaints, specifically on this issue, have already be filed and are currently being
investigated by your office under the Code and the Act.
REQUEST
We respectfully request that you accept the foregoing and:

1. Undertake the necessary inquiries of the MPs identified herein as contravening the
Code, and recommend appropriate sanctions for each such contravening MP; and,
2. Undertake the necessary examinations of the Public Office Holders identified herein as
contravening the Act, and assess the appropriate penalties for each such contravening
Public Office Holder.
Yours sincerely,
Martha Hall Findlay
MP for Willowdale
Liberal Critic for Public Works and Government Services

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APPENDIX 1:
Letter to the Treasury Board
See attached.
HOUSE OF COMMONS
CHAMBRE DES COMMUNES
CANADA
MARTHA HALL FINDLAY

MEMBER OF PARLIAMENT / DÉPUTÉE
WILLOWDALE
October 8, 2009
To: Members of the Treasury Board:

The Hon. Vic Toews, President of the Treasury Board (Chair)
The Hon. Rona Ambrose, Minister of Labour (Vice-Chair)
The Hon. James Flaherty, Minister of Finance
The Hon. Jay Hill, Leader of the Government in the House of Commons
The Hon. Diane Ablonczy, Minister of State (Small Business and Tourism)
The Hon. Steven Fletcher, Minister of State (Democratic Reform)
Re: Partisan Nature of Government of Canada Advertising
I write to express serious concern about the partisan nature of the Conservative government’s
taxpayer-funded advertising campaign for its economic program, and to ask that all partisan
aspects of this campaign stop immediately.
This campaign and related government publications are in breach of federal law and the
Government of Canada’s own communication policies. The partisan nature of television, radio
and print advertisements, government-funded publications, and websites such as
www.actionplan.gc.ca and www.planandaction.gc.ca, violate the following:
(i) Treasury Board Secretariat policies under the Financial Administration Act;
(ii) The Conflict of Interest Code for Members of the House of Commons;
(iii) The Conflict of Interest Act incorporated into the Federal Accountability Act, and
(iv) Party financing provisions of the Canada Elections Act.
I ask that the government (i) acknowledge that publicly-funded government advertising is not
to be used to benefit any political party; (ii) immediately remove all explicit and implicit
partisan aspects of its taxpayer-funded television, radio and website content; and (iii)
immediately stop its use of partisan material and messaging in taxpayer-funded print copy.

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Taxpayers should not pay for advertising designed to influence their own votes. Government of
Canada advertising, promotion and assets are NOT to be used for partisan benefit and it is the
Treasury Board’s job to ensure integrity and accountability with regard to all government-wide
advertising.
Treasury Board Communications Policy and the Federal Identity Program
All communications from the Government of Canada must comply with the Treasury Board
Communications Policy and the Federal Identity Program Policy.
The Communications Policy explicitly requires that all Government of Canada communications
be “objective,” and “inform the public in an accountable, non-partisan fashion consistent with
the principles of Canadian parliamentary democracy and ministerial responsibility.” All
communications must “ensure that public trust and confidence in the impartiality and integrity
of the Public Service of Canada are upheld,” and “avoid conflicts of interest and the appearance
or public perception of endorsing, or providing a marketing subsidy or an unfair competitive
advantage to any person, organization or entity outside of government.” The Conservative
Party is an “entity outside of government”—or at least by law it should be. The government’s
communications relating to its economic program are in violation of the letter as well as the
spirit of these rules.
Under the Federal Identity Program, all Government of Canada communications, including
advertising, must use only approved national symbols and clearly refer to the government as
the “Government of Canada.” The overwhelming use of the phrase “Harper Government,”
instead of the appropriate phrase “Government of Canada” in taxpayer-funded government
advertisements, publications and websites is wrong. The word “Harper” is not an approved
applied title for federal advertising purposes.
The many photos of Stephen Harper and the dominant use of Conservative Party blue in
television ads, publications, print ads and Government websites also violate these rules. In
addition, the Conservative government’s publicly-funded advertising duplicates, and therefore
endorses, partisan Conservative slogans and tag lines, such as “stay the course” and “we can’t
stop now,” used in Conservative Party slogans, press releases and speeches.
The Treasury Board Communications Policy and the Federal Identity Program are clear: the
Government cannot use public funds to confer a clearly partisan benefit upon Stephen Harper
personally or upon the Conservative Party generally. By violating these rules with its
advertising practices, this Conservative government is violating public trust.

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Conflict of Interest Rules for Members of Parliament
Conflict of interest provisions have bound Members of Parliament, including the Prime
Minister and members of his/her Cabinet, for years. The principles guiding these provisions are
set out in Section 2 of the Conflict of Interest Code for Members of the House of Commons. This
code holds that MPs must, among other things, “fulfill their public duties with honesty and
uphold the highest standards so as to avoid real or apparent conflicts of interest.” In the
context of these principles, the code requires that an MP “not act in any way to further his or
her private interests … or to improperly further another person or entity’s private interests”,
and “not use his or her position … to influence a decision of another person so as to …
improperly further another person’s or entity’s private interests .” Condoning and promoting
the use of publicly funded government advertising to benefit the Conservative party is a clear
violation of these principles and the provisions of the code by the Conservative government,
the Prime Minister and Cabinet.
The Conflict of Interest Act
The Conservative government has broken the very laws it enacted as part of the Federal
Accountability Act. The Conflict of Interest Act applies the provisions of the above mentioned
code to all public office holders and holds that:
 A public office holder is in a conflict of interest when he or she exercises an official

power, duty or function that provides an opportunity to further his or her private
interests or those of his or her relatives or friends or to improperly further another
person’s private interests. (Section 4);
and that:
 No public office holder shall use his or her position as a public office holder to seek
to influence a decision of another person so as to further the public office holder’s
private interests or those of the public office holder’s relatives or friends or to
improperly further another person’s private interests. (Section 9).
The Conservative government’s use of publicly-funded government advertising to confer a

benefit upon the Conservative Party violates this law. The role of the Conservative government
in ensuring the presence of partisan messaging in its publicly-funded advertising also raises
concerns about the role of the Privy Council Office in this matter.

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Canada Elections Act
The partisan nature of this government’s advertising and promotion also contravenes the
Canada Elections Act as an ineligible non-monetary contribution made by the government—in
effect, Canadian taxpayers—to the Conservative Party.
Elections Canada contribution rules are clear and strict: only individuals can make donations to
political parties (no other organizations or entities are allowed to do so) (s. 404(1)), and
individuals cannot contribute more than $1,100 annually to a national party (s. 405(1)).
Advertising by a third party, such as the Government of Canada, that promotes a political party,
even indirectly, amounts to a “service” benefitting that political party in the form of a “non-
monetary contribution” by the third party. Provision of this “service” can include the use of the
benefitting political party’s politicians’ surnames, partisan catch-phrases and/or slogans, party
colours where other colours would otherwise be appropriate, and by otherwise showing a
particular political party in a favourable light.
This value of this “service” is significant--advertising that is carried on television, radio, print
and/or the Internet has a significant commercial value.
Section 404 (2) provides that “if a registered party ... receives a contribution from an ineligible
contributor ... the chief agent of the registered party ... shall, within 30 days after becoming
aware of the ineligibility, return ... in the case of a non-monetary contribution, an amount equal
to its commercial value, to the Chief Electoral Officer who shall forward that amount to the
Receiver General.”
According to Section 405.2 (1): No person or entity shall:
(a) circumvent, or attempt to circumvent, the prohibition under subsection 404(1), or
(b) act in collusion with another person or entity for that purpose.
In addition to the requirement to return the value of the service/contribution, there are
significant penalties for breaching the Act.
Request for Action
Given the clear violations of both the letter and the spirit of various laws and government
policies by the Conservative government, I repeat my request that the Government
immediately remove all partisan aspects in its taxpayer-funded television, radio and website
content, and that the Government immediately stop its use of this partisan material and
messaging in taxpayer-funded print advertising and other publications.

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I look forward to hearing your response and to seeing this government immediately take the
action necessary to ensure that, as required, all Government of Canada communications be
“objective,” and that such communications are used only to “inform the public in an
accountable, non-partisan fashion consistent with the principles of Canadian parliamentary
democracy and ministerial responsibility.”
Sincerely,
Martha Hall Findlay
MP for Willowdale
Liberal Critic for Public Works and Government Services
cc: The Hon. Christian Paradis, Minister of Public Works and Government Services
cc: Michelle d'Auray, Secretary of the Treasury Board
cc: Wayne Wouters, Clerk of the Privy Council and Secretary to the Cabinet

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Page 1 of 8
APPENDIX 2:
Transcripts of Television and Radio Advertisements Promoting the Government’s Budgetary
Economic Programs
Contents
TELEVISION Advertisements ........................................................................................................... 2
1. What it Means...................................................................................................................... 2
2. Home Renovation Tax Credit (Concept 2) ........................................................................... 3
RADIO Advertisements ................................................................................................................... 4
3. Canada’s Economic Action Plan – Forestry.......................................................................... 4
4. Canada’s Economic Action Plan – Automotive .................................................................... 5
5. Canada’s Economic Action Plan – Employment Insurance / Skills Training ........................ 6
6. Canada’s Economic Action Plan – Manufacturing ............................................................... 7
7. Canada’s Economic Action Plan – Home ............................................................................. 8
Page 2 of 8
TELEVISION Advertisements
1. What it Means - Department of Finance Canada

http://www.actionplan.gc.ca/eng/feature.asp?pageId=104
To me, it means we're dealing with the global economic crisis.

It means we've got a plan.
It means I can learn new job skills.
It means Canada is getting stronger.
We're getting back on our feet again.
It means people are getting help
But we have to stay on track.
To me, it means jobs are being created
We can get a tax credit for home renos
Workers are being supported.
Canada's Economic Action Plan?
To me, it means I can do my research.
It means I can get my staff new computers
and I can keep all my employees.
It means real tax cuts - right when we need them.
It means new opportunities for everyone
coast to coast to coast
in every province - and territory.
For me it means a better future.
It means that when this is all over, we're going to come out stronger than ever.
Canada's Economic Action Plan. Find out what's in it for you.
A message from the Government of Canada.
Page 3 of 8
2. Home Renovation Tax Credit (Concept 2) - Canada Revenue Agency

I pick the home improvements; my husband gets to figure them out, eventually.
The home renovation tax credit gives us a good reason to do it now. We can save up to
1350 dollars on home improvements purchased before February 2010. We just have to
remember to keep our receipts for when we file our taxes.
This envelope is great.
Putting our tax dollars back into our home; that works for us.
Canada’s Economic Action Plan. Get started now at actioncanada.gc.ca.
Page 4 of 8
RADIO Advertisements
3. Canada’s Economic Action Plan – Forestry - Department of Finance Canada

The Government of Canada’s proposed Economic Action Plan contains new measures to
benefit the communities, businesses and families that depend on forestry related jobs.
This support will help Canadians companies better compete globally by developing new
products and aggressively marketing them.
New measures to make machinery more affordable will also help reduce operating costs
and keep jobs in Canada.
Canada’s Economic Action Plan. Visit actionplan.gc.ca or call 1 800 0 Canada.
A message from the government of Canada.
Page 5 of 8
4. Canada’s Economic Action Plan – Automotive - Department of Finance Canada

benefit those who depend on our automotive industry.
This includes significant tax relief to help auto manufacturers compete globally, while
improving access to financing for auto parts manufacturers and helping consumers and
businesses finance vehicle and equipment purchases here at home.
Page 6 of 8
5. Canada’s Economic Action Plan – Employment Insurance / Skills Training -

Department of Finance Canada
The Government of Canada’s proposed Economic Action Plan contains new measures that
may benefit you.
To help unemployed Canadian workers, regular employment insurance benefits could be
extended by five extra weeks. And new investments in skills training could mean access to
programs and opportunities that could help Canadians get back to work.
Page 7 of 8
6. Canada’s Economic Action Plan – Manufacturing - Department of Finance Canada

benefit the communities, businesses and families that depend on manufacturing jobs.
This support includes real tax relief that will encourage investment in computers, machinery
and equipment that will make our manufacturers more competitive and help keep jobs in
Canada.
Page 8 of 8
7. Canada’s Economic Action Plan – Home – Department of Finance Canada

The Government of Canada has proposed new tax cuts that may benefit you.
As part of Canada’s Economic Action plan, tax cuts, like the home renovation tax credit,
could save you up to 1350 dollars on renovations completed before next February.
There are also EcoEnergy retrofit grants and savings for first time home buyers. So reach
out and claim them.
Learn more about Canada’s Economic Action Plan at actionplan.gc.ca or call 1 800 0 Canada.
APPENDIX 3:
Communications Tools Contravening Law and Policy: Print and Online Advertisements
Contents
Unsubstantiated, false and/or exaggerated claims of accomplishment ........................................ 2
1. 90% Of The Plan Has Been Committed – Website .............................................................. 2
2. 80% Of The Plan Has Been Implemented ............................................................................ 5
Banner Ads ...................................................................................................................................... 6
3. National Post ........................................................................................................................ 6
4. Toronto Star ......................................................................................................................... 7
5. Macleans.ca ......................................................................................................................... 8
6. Canada.com ......................................................................................................................... 9
7. Le Devoir ............................................................................................................................ 10
8. Vancouver Sun ................................................................................................................... 11
9. Global TV ............................................................................................................................ 12
10. Government of Canada Website .................................................................................... 13
Print Advertisement ...................................................................................................................... 14
11. Creating Jobs Today ....................................................................................................... 14
English ................................................................................................................................... 14
French: .................................................................................................................................. 16
Other ............................................................................................................................................. 17
12. Creating Jobs Today - GO Train Wrap, Toronto ............................................................. 17
Unsubstantiated, False and/or Exaggerated Claims of Accomplishment
1. 90% Of The Plan Has Been Committed – Website
28 September 2009
http://www.actionplan.gc.ca/eng/media.asp?id=1952
2. 80% Of The Plan Has Been Implemented
Government of Canada Report to Canadians on the Economic Action Plan in Conservative

Blue with Misleading Claim Lacking Support of Evidence
Banner Ads
3. National Post
http://www.nationalpost.com/
4. Toronto Star
http://www.thestar.com/
5. Macleans.ca
http://www2.macleans.ca/
6. Canada.com
http://www.canada.com/
7. Le Devoir
http://www.ledevoir.com/
8. Vancouver Sun
http://www.vancouversun.com/index.html
9. Global TV
www.globaltv.com/globaltv/index.html
10. Government of Canada Website
http://www.canada.gc.ca/home.html
Print Advertisement
11. Creating Jobs Today
Representative List of Media Outlets Running this advertisement on October 6 and 7
English :
Appearences in English media:
The Gulf News (Port aux Basques) | 5 Oct 2009 | Canada | English | Page: 10
Advertiser (Grand Falls) | 8 Oct 2009 | Canada | English | Page: 24
The Charter | 5 Oct 2009 | Canada | English | Page: 16
The Chronicle (Montreal) | 7 Oct 2009 | Canada | English | Page: 2
Nor'wester (Springdale) | 8 Oct 2009 | Canada | English | Page: 8
The Beacon (Gander) | 8 Oct 2009 | Canada | English | Page: 16
The Aurora (Labrador City) | 5 Oct 2009 | Canada | English | Page: 32
The Kings County Advertiser | 6 Oct 2009 | Canada | English | Page: 22
Coaster (Harbour Breton) | 6 Oct 2009 | Canada | English | Page: 2
Southwest Booster | 8 Oct 2009 | Canada | English | Page: 11
The Digby County Courier | 8 Oct 2009 | Canada | English | Page: 13
The Kings County Register | 8 Oct 2009 | Canada | English | Page: 14
Sackville Tribune | 7 Oct 2009 | Canada | English | Page: 32
The Record (Springhill) | 7 Oct 2009 | Canada | English | Page: 24
The Annapolis County Spectator | 8 Oct 2009 | Canada | English | Page: 36
The Hants Journal | 8 Oct 2009 | Canada | English | Page: 36
The Queens County Advance | 6 Oct 2009 | Canada | English | Page: 24
Le Magazine de l'Iles-des-Soeurs | 8 Oct 2009 | Canada | French | Page: 35
Le Messager La Salle | 8 Oct 2009 | Canada | French | Page: 29
Le Messager Verdun | 8 Oct 2009 | Canada | French | Page: 15
Le Messager Lachine & Dorval | 8 Oct 2009 | Canada | French | Page: 16
Corriere Italiano | 7 Oct 2009 | Canada | Italian | Page: 19
The Yarmouth County Vanguard | 6 Oct 2009 | Canada | English | Page: 24
The Shelburne County Coast Guard | 6 Oct 2009 | Canada | English | Page: 13
The Pilot | 7 Oct 2009 | Canada | English | Page: 14
The Gazette | 8 Oct 2009 | Canada | English | Page: 71
Advertiser (Grand Falls) | 5 Oct 2009 | Canada | English | Page: 2
Northern Pen | 5 Oct 2009 | Canada | English | Page: 28
The Georgian (Stephenville) | 6 Oct 2009 | Canada | English | Page: 8
The Packet (Clarenville) | 8 Oct 2009 | Canada | English |
The Compass | 6 Oct 2009 | Canada | English | Page: 7
The Southern Gazette | 6 Oct 2009 | Canada | English
French:
Appearances in French media:
Avenir PaT - Montreal-Est | 6 Oct 2009 | Canada | French | Page: 22

Flambeau Mercier-Anjou | 6 Oct 2009 | Canada | French | Page: 31
L'Informateur | 6 Oct 2009 | Canada | French | Page: 8
Guide de Montreal-Nord | 6 Oct 2009 | Canada | French | Page: 18
Progres Saint-Leonard | 6 Oct 2009 | Canada | French | Page: 14
Le Plateau | 8 Oct 2009 | Canada | French | Page: 2
Journal De Rosemont | 6 Oct 2009 | Canada | French | Page: 23
Le Progres Villeray | 6 Oct 2009 | Canada | French | Page: 16
Courrier Laval | 7 Oct 2009 | Canada | French | Page: 14
Le Courrier Sud | 7 Oct 2009 | Canada | French | Page: 2
Other
12. Creating Jobs Today - GO Train Wrap, Toronto
Page 1 of 15
APPENDIX 4:
Communications Tools Contravening Law and Policy: Websites and Weblinks
Contents
Action Plan Website, Social Media Links to Personal Accounts ..................................................... 2
1. Facebook .............................................................................................................................. 2
2. Flickr ..................................................................................................................................... 4
3. Twitter .................................................................................................................................. 6
4. YouTube ............................................................................................................................... 8
5. MySpace ............................................................................................................................. 10
Website layout .............................................................................................................................. 12
6. Action Plan Website ........................................................................................................... 12
7. Conservative Party Website............................................................................................... 13
Advertisements Referring to Action Plan Website ....................................................................... 14
8. RADIO ................................................................................................................................. 14
Canada’s Economic Action Plan – Home Renovation ........................................................... 14
9. TELEVISION......................................................................................................................... 14
Home Renovation Tax Credit ................................................................................................ 14
Page 2 of 15
Action Plan Website, Social Media Links to Personal Accounts
1. Facebook
October 16, 2009 and October 23, 2009 – Weblink from actionplan.gc.ca to Prime
Minister Harper’s personal Facebook Profile.
The first graphic below, a screenshot taken on October 16, 2009, indicates that the subject link
was inappropriately directed to Stephen Harper’s personal Facebook page, and the second
graphic below demonstrates that the same link was changed by October 23, 2009.
October 16, 2009

Page 3 of 15
October 23, 2009

Page 4 of 15
2. Flickr
October 16, 2009 and October 23, 2009 - Weblink from actionplan.gc.ca to Prime
Minister Harper’s personal Flickr feed.
was inappropriately directed to Stephen Harper’s personal Flickr feed, and the second graphic
below demonstrates that the same link was changed by October 23, 2009.
October 16, 2009

Page 5 of 15
October 23, 2009

Page 6 of 15
3. Twitter
Minister Harper’s personal Twitter feed.
was directed to Stephen Harper’s personal Twitter feed, and the second graphic below
demonstrates that the same link was changed by October 23, 2009.
October 16, 2009

Page 7 of 15
October 23, 2009

Page 8 of 15
4. YouTube
Minister Harper’s personal YouTube channel.
was directed to Stephen Harper’s personal YouTube channel, and the second graphic below
October 16, 2009

Page 9 of 15
October 23, 2009

Page 10 of 15
5. MySpace
Minister Harper’s personal MySpace page.
was directed to Stephen Harper’s personal MySpace page, and the second graphic below
October 16, 2009

Page 11 of 15
October 23, 2009

Page 12 of 15
Website layout
6. Action Plan Website
http://www.actionplan.gc.ca/eng/index.asp
The layout of this website is virtually identical to the layout of the Conservative Party’s
own website (in item 3 below). For further comparison of similarities please see
appendix 6.
Page 13 of 15
7. Conservative Party Website

http://www.conservative.ca/
Page 14 of 15
Advertisements Referring to Action Plan Website
8. RADIO
Canada’s Economic Action Plan – Home Renovation

The Government of Canada’s proposed Economic Action Plan contains new tax
measures that may benefit you.
For a limited time, the new home renovation tax credit mean that homeowners may
receive up to 1350 dollars in tax relief on renovation expenses.
And first time home buyers can save up to 750 dollars on the closing costs of a new
home.
9. TELEVISION
Home Renovation Tax Credit

When it comes to home improvements, we tend to put things off.

The home renovation tax credit gives us a good reason to get started now on those
improvements we’ve been thinking about.
It means we can save up to 1350 dollars on home improvements purchased before
February 2010.
We just have to remember to keep our receipts for when we file our taxes.
Page 15 of 15
This envelope is really handy. Putting our tax dollars back into our home; that works for
us.
Canada’s Economic Action Plan. Get started now at actioncanada.gc.ca.
Page 1 of 15
APPENDIX 5:
Official Letters and Other Examples
Contents
Official Letters from Government Ministers .................................................................................. 2
1. Letter to Constituents from the Honourable Lisa Raitt, Minister of Natural Resources..... 2
Government of Canada documents referring to the Government of Canada as the “Harper
Government” .................................................................................................................................. 3
2. “The Harper Government” on Government of Canada websites (“gc.ca”)......................... 3
Google Search conducted October 6, 2009 ............................................................................ 3
Updated search 10 days later (Oct. 16) shows 9,350 mentions ............................................. 4
3. Canada’s Economic Action Plan Website: What has been done. ........................................ 5
Canada News Centre ................................................................................................................... 7
4. PM announces improvements to Toronto Reference Library...................................... 7
5. Prime Minister Stephen Harper and Alberta Premier announce cutting-edge clean
energy project ......................................................................................................................... 8
6. Harper Government Investment to Benefit Communities Across British Columbia ... 9
7. Harper Government Invests In Fort Nelson's Recreational Infrastructure ................ 10
8. Harper Government Announces Investment to Create Jobs In Vernon .................... 11
9. Harper Government Delivering Action to Support Home Owners: Invests in the
Economy................................................................................................................................ 12
Natural Resources Canada News Room ................................................................................... 13
Economy................................................................................................................................ 13
Western Economic Diversification Canada ............................................................................... 15
11. Harper Government Announces Investments to Help Create & Maintain Jobs in
Manitoba ............................................................................................................................... 15
Page 2 of 15
Official Letters from Government Ministers

1. Letter from Minister of Natural Resources
Letter with Conservative Branding from the Honourable Lisa Raitt, Minister of Natural
Resources violating Treasury Board Communications Policy and the Federal Identity Program
Policy.
Page 3 of 15
Government of Canada documents referring to the Government of Canada as

the “Harper Government”
2. “The Harper Government” on Government of Canada websites (“gc.ca”)
Google Search conducted October 6, 2009

Page 4 of 15
Updated search 10 days later (Oct. 16) shows 9,350 mentions

Page 5 of 15
3. Canada’s Economic Action Plan Website: What has been done.

http://actionplan.gc.ca/eng/feature.asp?featureId=4
Page 6 of 15
Page 7 of 15
Canada News Centre

4. PM announces improvements to Toronto Reference Library
http://news.gc.ca/web/article-eng.do?m=/index&nid=490309
Page 8 of 15
5. Prime Minister Stephen Harper and Alberta Premier announce cutting-edge clean
energy project
http://news.gc.ca/web/article-eng.do?m=/index&nid=489629
Page 9 of 15
6. Harper Government Investment to Benefit Communities Across British Columbia

http://news.gc.ca/web/article-
eng.do?crtr.sj1D=&mthd=advSrch&crtr.mnthndVl=&nid=480989&crtr.dpt1D=&crtr.tp1D=&crtr.
lc1D=&crtr.yrStrtVl=&crtr.kw=%2522harper%2Bgovernment%2522&crtr.dyStrtVl=&crtr.aud1D=
&crtr.mnthStrtVl=&crtr.yrndVl=&crtr.dyndVl
Page 10 of 15
7. Harper Government Invests In Fort Nelson's Recreational Infrastructure

Page 11 of 15
8. Harper Government Announces Investment to Create Jobs In Vernon

Page 12 of 15

Economy
lc1D=&crtr.yrStrtVl=&crtr.kw=%2522conservative%2Bgovernment%2522&crtr.dyStrtVl=&crtr.a
ud1D=&crtr.mnthStrtVl=&crtr.yrndVl=&crtr.dyndVl
Page 13 of 15
Natural Resources Canada News Room
Economy
http://www.nrcan-rncan.gc.ca/media/newcom/2009/200955-eng.php
Page 14 of 15
Page 15 of 15
Western Economic Diversification Canada
11. Harper Government Announces Investments to Help Create & Maintain Jobs in
Manitoba
http://www.wd.gc.ca/eng/77_11594.asp
Page 1 of 9
Appendix 6
Conservative Party Speeches and Communications Tools
Contents
Comparisons .......................................................................................................................................................... 2
1. Conservative Party Platform Document (Federal Election 2008) and the Government of Canada’s Speech
From The Throne (November 2008) ..........................................................................................................................2
2. conservative.ca and actionplan.gc.ca...............................................................................................................3
Releases from Conservative.ca, As Compared to Advertising of Budgetary Economic Programs............................ 4
1. Prime Minister Stephen Harper addressed the Canadian Chamber of Commerce ...........................................4
2. PM announces federal contribution to Linamar for leading edge research and development projects...........5
3. PM announces construction of new small craft harbour in Pangnirtung .........................................................6
4. PM announces improvements to Toronto Reference Library ...........................................................................7
5. Clean Energy for Tomorrow: Investing in Carbon Capture and Storage in Alberta ..........................................8
6. PM highlights Government Investments in Small Businesses in Canada ..........................................................9

Page 2 of 9
Comparisons
1. Conservative Party Platform Document (Federal Election 2008) and the

Government of Canada’s Speech From The Throne (November 2008)
2008 Conservative Party Platform 2008 - Speech from the Throne

Page 3 of 9
2. conservative.ca and actionplan.gc.ca
Conservative.ca header on top, actionplan.gc.ca header on bottom. Both conservative.ca and

actionplan.gc.ca contain exactly the same colours, custom fonts and custom spacing in their respective
headers (#333399). These websites have also been formatted and laid out identically (as evidenced by
the screenshots included in Appendix 4).
Page 4 of 9
Releases from Conservative.ca, As Compared to Advertising of Budgetary

Economic Programs
1. Prime Minister Stephen Harper addressed the Canadian Chamber of Commerce

http://www.conservative.ca/EN/1091/111049
Overlap with Government Advertising of Budgetary Economic Programs (emphasis added):
* “We must stay on course and finish implementing our Economic Action Plan.”
* “On September 28, the Prime Minister presented “Staying on Course,” the Government’s Third Report
to Canadians on the government’s Economic Action Plan.“
* “Our government remains focussed on helping Canadians and is committed to staying on course to
ensure our economic recovery is strong.”
* Reference to actionplan.gc.ca
Page 5 of 9
2. PM announces federal contribution to Linamar for leading edge research and

development projects
Overlap with Government Government Communications of Budgetary Economic Programs (emphasis

added):
* “With projects like the Green and Fuel Efficient Powertrain Projects, we are seizing the opportunities
that will get us through these tough times, ensuring our country emerges stronger than ever and
creating high-quality jobs in communities like Guelph.”
Page 6 of 9
3. PM announces construction of new small craft harbour in Pangnirtung


added):
* “Our government views Canada as a country that stretches from coast to coast to coast and our
Economic Action Plan is backing up this northern vision with real action,”
Page 7 of 9
4. PM announces improvements to Toronto Reference Library


added):
*“Our Economic Action Plan is putting Canadians to work from coast to coast to coast on more than
4,000 infrastructure projects, including 500 right here in Toronto.
*While we are seeing encouraging signs of recovery, Canada isn’t out of the woods yet. Just as we were
dragged into this global recession through no fault of our own, our recovery could be affected by
economic events beyond our borders, or political instability at home. That is why we must stay on
course, complete the implementation of our Plan and finish the job of building the foundations of
Canada’s future prosperity!
Page 8 of 9
5. Clean Energy for Tomorrow: Investing in Carbon Capture and Storage in Alberta

added):
*“As I have said, now is not the time for political uncertainty or instability. Now is the time to stay on
course, to finish implementing our Plan, and to strengthen the foundations of Canada’s future
prosperity!”
Page 9 of 9
6. PM highlights Government Investments in Small Businesses in Canada

Overlap with Government Communications of Budgetary Economic Programs

(emphasis added):
*“Our Government will continue to ensure small and medium-sized enterprises have the
opportunity to succeed and grow, despite the global economic downturn,” said the Prime
Minister. “Canada’s Economic Action Plan is delivering timely and targeted new initiatives to
help ensure that businesses come out of the recession stronger than ever. Our economy is
already showing signs of recovery and that recovery is being led by entrepreneurs.”
*The measures included in Canada’s Economic Action Plan are tax reductions for small
businesses, targeted investments to improve access to financing, increased availability of
venture capital, tax credits that encourage the purchase of new equipment and improved
access to the Government of Canada’s business services.
*The Government is working closely with entrepreneurs and business owners to strengthen this
foundation and make Canada an innovative and competitive leader on the global stage.

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HOUSE OF COMMONS

CHAMBRE DES COMMUNES

MARTHA HALL FINDLAY

October 27, 2009

BY HAND AND BY FAX

Mary Dawson, Conflict of Interest and Ethics Commissioner Office

Dear Ms. Dawson,

We have not received a response from the Treasury Board.

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

CONFLICT OF INTEREST OF CODE FOR MEMBERS OF THE HOUSE OF COMMONS

Violations of the Code

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

The Minister of Natural Resources and her Parliamentary Secretary, and

THE CONFLICT OF INTEREST ACT

Violations of the Act

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

CONSERVATIVE BRANDING IN THE CAMPAIGN

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

We respectfully request that you accept the foregoing and:

Martha Hall Findlay

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

MARTHA HALL FINDLAY

To: Members of the Treasury Board:

Re: Partisan Nature of Government of Canada Advertising

(iv) Party financing provisions of the Canada Elections Act.

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

Treasury Board Communications Policy and the Federal Identity Program

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

Conflict of Interest Rules for Members of Parliament

The Conflict of Interest Act

 A public office holder is in a conflict of interest when he or she exercises an official

The Conservative government’s use of publicly-funded government advertising to confer a

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

Canada Elections Act

According to Section 405.2 (1): No person or entity shall:

(a) circumvent, or attempt to circumvent, the prohibition under subsection 404(1), or

Request for Action

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

Martha Hall Findlay

OTTAWA CONSTITUENCY OTTAWA CIRCONSCRIPTION

1. What it Means - Department of Finance Canada

To me, it means we're dealing with the global economic crisis.

2. Home Renovation Tax Credit (Concept 2) - Canada Revenue Agency

3. Canada’s Economic Action Plan – Forestry - Department of Finance Canada

4. Canada’s Economic Action Plan – Automotive - Department of Finance Canada

5. Canada’s Economic Action Plan – Employment Insurance / Skills Training -

6. Canada’s Economic Action Plan – Manufacturing - Department of Finance Canada

7. Canada’s Economic Action Plan – Home – Department of Finance Canada

Government of Canada Report to Canadians on the Economic Action Plan in Conservative

11. Creating Jobs Today

Representative List of Media Outlets Running this advertisement on October 6 and 7

Appearences in English media:

Appearances in French media:

Avenir PaT - Montreal-Est | 6 Oct 2009 | Canada | French | Page: 22

Action Plan Website, Social Media Links to Personal Accounts

October 16, 2009

October 23, 2009

October 16, 2009

October 23, 2009

October 16, 2009