Employee Code of Conduct


The City of Peterborough seeks to ensure a high level of public trust in City operations, programs and services.

Our Employee Code of Conduct establishes minimum expectations for the professional and ethical conduct of City employees based on the principles of integrity, honesty, impartiality, accountability, and openness.

If you believe an employee has breached the Code of Conduct, typically the first step is to speak directly with the employee or their supervisor to determine if the concern can be resolved.

If the concern cannot be resolved with the employee or the employee’s supervisor, or you are not satisfied with the response, you can submit a written complaint to the City of Peterborough.

A written complaint must be submitted within a reasonable time of the incident, preferably within five working days using the Code of Conduct Complaint Form. The online complaint form requires the complainant provide personal contact information. Anonymous Reporting is provided by a third-party service.

All complaints will be taken seriously and investigated in a way that is appropriate in the circumstances.

You will receive a reply to confirm that the complaint has been received.

Normally, the matter will be investigated within 30 days of receipt of the completed Code of Conduct Complaint Form.

Potential outcomes are confidential and are not shared with the complainant.

Make a Code of Conduct Complaint

Code of Conduct


The City of Peterborough (City) is committed to the principles of integrity, accountability and openness, and endeavors to maintain the highest level of public confidence and trust in all that we do.

The purpose of the Code of Conduct (the Code) is to establish minimum expectations for the professional and ethical conduct of City Employees.

The Code of Conduct recognizes that all City Employees are accountable to the City, City Council, and citizens of the City of Peterborough and have a responsibility to:

  • Uphold the basic principles of integrity, honesty, impartiality, and common sense and must not take advantage of his or her position to further personal interest.
  • Be accountable for the responsibilities entrusted to them and aware that every decision made on the job provides the opportunity to earn public trust through honesty and integrity of actions.
  • Demonstrate the highest standards of behaviour and be above reproach in their professional dealings.
  • Be professional and respectful in all communications and interactions with the public and all persons with whom they work.
  • Promote the goals, objectives and policies of the City and their respective department and to work collaboratively with co-workers to achieve those goals.

This Procedure applies to all City full-time, part-time, casual, and temporary employees, (collectively called “Employees”), as applicable to their position in the Corporation.

This Procedure will be applied in conjunction with all collective agreements, contracts, legislative requirements and/or standards identified by an Employee’s professional affiliations.


City – The Corporation of the City of Peterborough.

City Assets – All property, equipment, software, financial, digital, information, and time resources owned and or leased by the City.

Complainant – An individual who alleges that an Employee has breached this Code of Conduct.

Confidential Information – Information, in verbal or written form, that an Employee obtains access to through their position with the City and that is not available to the public, regardless of whether that information has been identified or labelled as confidential. Such information may be made available to the Employee partly, directly, or indirectly through any means of communication or observation.

Confidential Information includes:

  • Any information in the possession of, or received in confidence by, the City that the City is prohibited from disclosing, or has decided to refuse to disclose, under the Municipal Freedom of Information and Protection of Privacy Act, or any other law.
  • Personal Information
  • Information that is subject to solicitor-client privilege.
  • Information that concerns any confidential matters pertaining to personal, labour relations, legal proceedings, property acquisition or disposition, or the security of the property of the City.
  • All trade secrets, proprietary, and other information that is disclosed to or acquired by the Employee during or in the course of employment.
  • Any techniques, know-how, processes, or any combinations of any of them; any compilations of information, records, and specifications, used or owned by the City of Peterborough; and development, marketing, pricing, business methods, strategies, financial or other analyses, policies, or business opportunities.

Conflict of Interest – A situation in which an Employee has personal or private interests that may compete with the public interest of the City. A conflict may exist even if no unethical or improper act results from it. A Conflict of Interest can be Real, Potential, or Perceived Conflict.

Real Conflict – A situation in which an employee’s personal or private interests improperly influence the performance of official duties and responsibilities or where a position is used for personal gain or in personal circumstances.

Potential Conflict – A situation where an actual conflict could reasonably exist in the future if mitigation strategies are not followed.

Perceived Conflict – A situation where no actual conflict exists, however, the situation could be perceived by a reasonable observer to be a conflict, whether it is the case.

Employee – Paid staff of the City

Fraudulent Activity – An array of acts characterized by intentional deception. This includes:

  • Misrepresenting of information by an individual.
  • Misrepresenting information on documents.
  • Authorizing payment for goods and services not received.
  • Misappropriation of funds, securities, supplies, or any other asset.
  • Unauthorized use, destruction, or disappearance of City assets or information.
  • Forgery or alternation of documents.
  • Any other deliberately deceitful, dishonest, or untrue actions to secure unfair or unlawful gain.

Outside Activities – Any work or endeavour that an Employee commits to or engages in beyond their job with the City. Such endeavours may consist of paid employment, participation in non-profit activities, or volunteer activities.

Personal Information – Recorded information about an identifiable individual.

Political Activity – Activities such as canvassing, campaigning, or fundraising that aim to advance an individual’s or group’s political interests.

Public Criticism – The act of expressing disapproval in open view.

Respondent – A person who is alleged to have breached the Code of Conduct and is the subject of a Formal Complaint process.

Standards of Conduct

All Employees must ensure that their personal and professional conduct conforms with the expectations set out below.

Personal/Professional Conduct

  • Employees, as representatives of the City, must conduct themselves with the highest degree of professional and ethical behaviour.
  • Employees must perform their duties with honesty and integrity, in a professional manner that is helpful, respectful, and courteous.
  • Employees must also be professional and courteous with their co-workers and be aware that improper behaviour in the workplace has a negative affect on others. For further information, refer to the City’s Workplace Discrimination and Harassment Policy.

Public Criticism

  • Employees are ambassadors of the City, and as such, must reflect a professional image and present the City in a positive light.
  • Employees are expected to support implementation and application of the policies, programs and decisions of the City regardless of how they may feel personally.
  • Employees are expected to refrain from expressing Public Criticism towards the City as an institution or employer or for a decision made, such that the public’s perception could be adversely affected.
  • Public Criticism may include but is not limited to letters to the editor, interviews with the media, negative statements to the public and posts on social media sites.
  • If an Employee self-identifies as an Employee of the City on a personal social media site, they must:
    • Make it clear that they are expressing personal views and are not commenting in their professional role as an Employee of the City.
    • Be aware that they may still be held accountable for personal posts if such posts are shown to detrimentally affect the City’s reputation, business interests, or operations.
  • Employees are accountable for their comments and actions, both inside and outside of the workplace. Any comments, statements, or opinions about Council decisions, fellow Employees or the workplace that are or perceived to be negative, derogatory etc. may be in contravention of this Code of Conduct or any other City policies may result in disciplinary action.
Conflict of Interest

The Public interest always prevails over a private interest, regardless of the circumstances.

Employees must be free from undue influence and must not act or appear to act in order to gain financial or other benefits for themselves, family, friends, or business interests.

Employees must not participate in situations where their personal interests’ may conflict with the interests of the City or with their employment responsibilities, regardless of whether that conflict is a Real, Potential, or Perceived Conflict.

Employees must avoid situations that even appear to be a Conflict of Interest. Competing interests make it difficult for Employees to fulfill their duties impartially. A Conflict of Interest can create an appearance of impropriety or a perception of bias that can undermine confidence in the person and in the City generally.

Employees must never give special treatment to relatives, friends, or organizations. Business decisions at work must not benefit an Employee personally or their families or friends, either directly or indirectly.

Employees must not participate in the appointment, promotion or hiring of a person with whom the Employee has a marital, familial, or sexual relationship.

Conflicts of Interest can arise in a variety of situations including, but not limited to the following examples which are explained in further detail in separate sections of the Code of Conduct procedure.

Personal Gain, Benefit, Favouritism and Gifts

Employees must not accept or provide any gift, benefit, or favour in exchange for special consideration or influence, or where it may be perceived to be in exchange for special treatment.

Employees must not participate in and must remove themselves from any decision process that may result in a real, potential or perceived personal gain, favouritism, or benefit. Examples of such decision processes include, but are not limited to:

  • Recommending or endorsing products, services, or suppliers.
  • Awarding of City tenders or job opportunities.
  • Land sales and disposal of surplus assets.

City decision processes must be carried out impartially, without any advantage or favouritism to Employees or others.

Employees must not solicit, accept, or condone the solicitation or acceptance of, any gift, favour or hospitality from any person or business, having dealings with the City.

City Assets

City Assets are only to be used for City purposes. They are to be used by Employees only for the performance of their City duties, and not for personal gain or benefit.

Employees may not use City Assets for personal gain under any circumstances and may not misuse any City Asset where such use could be deemed offensive, inappropriate, or fraudulent.

Employees must devote themselves exclusively to the performance of their employment duties during paid working hours.

Employees must ensure that any City Assets that are in their care, are properly secured and protected at all times.

Employees must return all City property to the Corporation upon termination of employment, all equipment, including computer hardware and software, keys, purchasing cards, or clothing issue.

Employees must abide by all policies related to information technology and the privacy and security of data information technology resources as set out in the Information Technology policies.

Employees must protect information stored on computers and use these tools in a responsible manner. This includes the disposal of surplus electronic devices and computers that can store Personal Information electronically or digitally, user access procedures, data backup, and virus protection procedures.

Outside Activities

Employees may not engage in Outside Activities or other business undertakings which could result in a Real, Potential, or Perceived Conflict of Interest. This includes any activities which:

  • Use unique knowledge or information related to the Employee’s employment with the City.
  • May negatively influence or affect the Employee in carrying out duties related to their employment with the City.
  • Takes place while on duty with the City.
  • Enables the Employee to derive some form of personal benefit by virtue solely of their employment with the City.
  • Is performed in a way as to appear to be an official act of or to represent the City.
  • Interferes with the delivery of City duties.
  • Involves the use of City resources.
  • Competes with and/or poses a Real, Potential, or Perceived Conflict of Interest with services provided by the City.
Political Activity

Employees are discouraged from direct involvement in the campaign of any candidate in a municipal election.

Employees must not engage in any Political Activity that:

  • Impairs or is perceived to impair the Employee’s ability to perform their duties impartially.
  • Is during the Employee’s normal working hours or is at their place of work.
  • Occurs while the Employee is representing or is perceived to be representing the City.
  • Results in a Real, Potential, or Perceived Conflict of Interest

While conducting their duties on behalf of the City, Employees must appear to be politically neutral.

Should an Employee wish to become a candidate in a municipal election, he or she may do so, provided that they comply with the requirements of the Municipal Act, 2001, the Municipal Elections Act, and any other relevant legislation.

Collection, Use and Disclosure of Confidential and Personal Information

Collection, use and disclosure of Confidential and Personal Information must be in accordance with the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) and for the purposes of carrying out City duties.

Employees may not disclose or use Confidential or Personal Information except as necessary to perform their City duties and in accordance with the provisions of MFIPPA.

Many Employees have access to Personal Information about other Employees or access to personal or financial information of members of the public.

  • This information must be kept confidential and secure and is only to be used for the purpose for which it was collected.
  • Employees must keep all Personal Information private and not disclose it. Employees must not use this information for personal gain or benefit of any kind.

Employees must not disclose or otherwise release Confidential Information without proper authorization.

Employees, having left the employment of the City, must not use or cause to be used, any Confidential Information gained or obtained in relation to their employment.

Financial Integrity

Employees who maintain the City’s financial and accounting records must do so with the utmost integrity, reflecting accurately and promptly all transaction, assets, and liabilities of the City.

All business records, expense records, invoices, bills, payroll and Employee records and other reports are to be prepared with care and honesty.

False or misleading entries, other false or misleading information, or omissions of entries in the records or reports of the City, or any unrecorded bank accounts, are strictly prohibited.

Employees must not undertake any Fraudulent Activities.

Employees must not misrepresent their need for employer provided income protection plans, including but not limited to Sick Leave, Short Term Disability, Long Term Disability, or other paid time off.

Employees must not misrepresent their need to an unpaid leave of absence, whether it be a job protected leave through the Employment Standards Act or approved through the City’s Leave of Absence Procedure.

Employees must not use City funds for any personal use at any time.

Professional Codes of Conduct

Employees with professional designations regulated by a professional college or other regulatory body may be subject to more than one code of conduct. These external Codes do not replace the obligations that Employees have under the City’s Code of Conduct and Employees should act to the highest standard.

Anonymous Reporting

As an added layer of ethical accountability to the City of Peterborough has an independent, third-party service provider that will receive anonymous reports of suspicion or proof of serious misconduct.

While it is preferred that any ethical misconduct is reported using the City’s regular Code of Conduct complaint process, we recognize that not everyone is comfortable coming forward with their concerns about potential or perceived misconduct. The independent, third-party service is a mechanism for anyone to bring forward credible information by anonymously reporting concerns of misconduct. This service allows our organization to set a new standard in ethical conduct. The purpose of this is to ensure that any potential misconduct is captured and investigated accordingly, increasing our accountability.

When submitting your report, ensure you include the information necessary to conduct a thorough investigation. Provide as many details as possible including names, dates, places, and the events that took place, as well as your perception of why the incident(s) may be a violation of the Code of Conduct.

Submission Online

Visit reporting.cornerstonegovernance.com

Enter the Login ID: pete75ON

Submission by Phone

Call toll-free 1-888-650-7768

You will be instructed to leave a voice message with the details of your report. The toll-free number does not subscribe to call display.