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Report To: General Government Committee
Date of Meeting: April 13, 2026 Report Number: LGS-021-26
Authored By: June Gallagher, Municipal Clerk
Submitted By: Rob Maciver, Deputy CAO/Solicitor, Legislative Services
Reviewed By: Mary-Anne Dempster, CAO
By-law Number: Resolution Number:
File Number:
Report Subject: Appointment of Integrity Commissioner – 2026-2030
Recommendations:
1.That Report LGS-021-26, and any related delegations or communication items, be
received;
2.That the Municipality of Clarington appoint Boghosian Allen LLP as Clarington’s
Integrity Commissioner in accordance with s. 223.3(1) of the Municipal Act, for the
Term of Council (2026-2030) commencing November 15, 2026, subject to the
Council of the Regional Municipality of Durham approving and authorizing the
appointment, as the Regional Municipality of Durham’s Integrity Commissioner with
the option to renew for an additional Council term;
3.That authority is granted to the Deputy CAO/Solicitor to execute an agreement with
Boghosian Allen LLP for the provision of Integrity Commissioner services for the
Term of Council (2026-2030) to implement the provisions of Report LGS-021-26 with
the terms similar to the Region of Durham;
4.That the by-law (Attachment 1 to Report LGS-021-26), repealing By-law 2022-39
and appointing Boghosian Allen LLP, as Clarington’s Integrity Commissioner, with
an effective date of the by-law being November 15, 2026, be approved;
5.That Staff be directed to update Clarington’s Accountability and Transparency
webpage following the appointment coming into effect; and
6.That all interested parties listed in Report LGS-021-26, be advised of Council’s
decision.
GG-074-26
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Report LGS-021-26
Report Overview
1. Legislative Authority
1.1 Subsection 223.3 (1) of the Municipal Act, 2001, as amended, grants the authority to
municipalities to appoint an Integrity Commissioner who reports to council and who is
responsible for performing in an independent manner the functions assigned by the
municipality.
2. Previous Agreement
2.1 Arising out of Report LGS-013-22, Clarington joined the retainer agreement with the
Region and appointed Principles Integrity to provide Integrity Commissioner services on
the payment of an annual retainer and hourly fee for service basis. Principles Integrity
was appointed by By-law 2022-039 for a term ending November 14, 2026.
3. Integrity Commissioner Responsibilities
3.1 The Integrity Commissioner shall have the following responsibilities outlined under
subsection 223.3 of the Municipal Act:
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Report LGS-021-26
3.2 As part of the reporting process, the Integrity Commissioner may recommend that
Council impose penalties in accordance with the Municipal Act, 2001 if, in the opinion of
the Integrity Commissioner, a Member of Council has contravened the Code of
Conduct.
3.3 The volume of calls/complaints cannot be predicted.
3.4 Clarington’s Code of Conduct Complaint Procedure detail the steps for receipt,
investigation, and resolution of complaints pursuant to the Code of Conduct. These
procedures are contained in Appendix A to the Council Code of Conduct and our
Accountability and Transparency webpage, including the Complaint Form.
4. Code of Conduct
4.1 The Council Code of Conduct helps to ensure that Members of Council engage and
debate using acceptable conduct. These standards should serve to enhance public
confidence that the Municipality’s elected representatives conduct Council Business in a
civil and courteous manner. By-law 2017-020, as amended, establishes the current
Clarington Code of Conduct.
4.2 There are currently no plans to review the Code of Conduct pending the Province’s
review and proposed changes regarding the Code of Conduct and Integrity
Commissioners. The Province had proposed legislation on several occasions but has
not passed any, as of the writing of this report. Bill 9, Municipal Accountability Act, 2025,
was sent to third reading on October 20, 2025 and proposes the following changes:
Currently, the Act provides that municipalities shall establish codes of conduct.
Re-enacted section 223.2 of the Act provides that the Lieutenant Governor in
Council may make regulations prescribing a code of conduct for members of
councils of municipalities and of local boards.
New section 223.3.1 of the Act requires the Integrity Commissioner of Ontario to
perform certain functions with respect to Integrity Commissioners, including
providing education and training to Commissioners.
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Report LGS-021-26
New section 223.4.0.1 of the Act provides that after conducting an inquiry under
section 223.4 of the Act, a Commissioner may make a recommendation to the
Integrity Commissioner of Ontario regarding whether the seat of the member who
is the subject of the inquiry be declared vacant. New section 223.4.0.2 of the Act
sets out the responsibilities of the Integrity Commissioner of Ontario upon
receiving such a recommendation, including the responsibility to conduct an
inquiry. Subsection 223.4.0.2 (4) of the Act sets out the actions the Integrity
Commissioner of Ontario is required to take upon completion of their inquiry.
New section 223.4.0.3 of the Act sets out the consequences where the Integrity
Commissioner of Ontario refers a matter back to the Commissioner. New section
223.4.0.4 of the Act sets out the consequences where the Integrity
Commissioner of Ontario recommends that a member’s seat be declared vacant,
including requiring the council of the municipality to vote on such
recommendation.
5. Discussion
Region’s Appointment
5.1 The process to secure integrity commissioner services for the next term of Council
followed the Region’s Consultant and Professional Services Contracting Procedure.
5.2 The appointment of an Integrity Commissioner was a coordinated effort between the
Region of Durham and the local municipalities.
5.3 The Region chose a “selection process”, similar to the practice in 2022, following the
Region’s Consultant and Professional Services Contracting Procedure. All Lower-tier
municipalities reviewed the Consulting Services Agreement (CSA) invitation letter and
provided input. Invitations to enter into a consulting and professional services contract
with the Region were sent to individuals/firms. Three proposals were received and
evaluated by Regional Staff. Respondents also participated in the presentation, and
interview sessions, which were evaluated by Regional Staff and representatives from
some of the Durham Region Clerks.
5.4 Similar to the previous two agreements, Durham's lower-tier municipalities were offered
the opportunity to “piggyback” on the Region’s agreement, which will result in individual
agreements with the municipalities and the Integrity Commissioner. The lower-tier
municipalities are under no obligation to appoint the same Integrity Commissioner as
the Region. However, appointing the same Integrity Commissioner as the Region allows
the Region and Municipality to undertake coordinated efforts to review the Council
Codes of Conduct, and for the Mayor and Regional Councillors to seek advice from one
source for matters that may come before both lower-tier and Regional Council.
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Report LGS-021-26
5.5 The Region has stated that “the overall scores between the three proponents were
incredibly close and references from existing clients were considered in the final
selection process. The interview panel concluded that each proponent, including the
Region’s current Integrity Commissioner, Principles Integrity, were capable of delivering
exceptional service in a vital transparency and oversight role.”
5.6 Based on the technical presentation, demonstration, and financial evaluation of the
compliant bid proposals submitted to the Region of Durham, Boghosian Allen LLP
achieved the highest combined score and was recommended for award.
6. Financial Considerations
6.1 The budget for the Integrity Commissioner is part of the “Administration-Professional
Fees” account for Legislative Services, which has $25,000 budgeted for 2026 and 2027.
Exact costs incurred on an annual basis depend on frequency of requests for advice
and number of investigations undertaken.
6.2 The following table shows the budgeted and actuals for this account in recent years.
2022
Budget
2022
Actual
2023
Budget
2023
Actual
2024
Budget
2024
Actual
2025
Budget
2025
Actual
$20,000
6.3 There is no cost for an annual retainer fee. It is anticipated that the Integrity
Commissioner will be called upon to provide at least one educational session.
7. Timing
7.1 The Region of Durham plans to take their report to Regional Council in April. As a result
of the timing of the Region’s recommendation report, Staff are recommending an
effective date tied to the Region’s decision.
7.2 The current Integrity Commissioner Agreement expires on November 14, 2026. If no
Integrity Commissioner is appointed, as per s. 223.3(1.1), “the municipality shall make
arrangements for all of the responsibilities set out in that subsection to be provided by a
Commissioner of another municipality.”
8. Strategic Plan
Not applicable.
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Report LGS-021-26
9. Climate Change
Not Applicable.
10. Concurrence
This report has been reviewed by the Deputy CAO/Treasurer who concurs with the
recommendations.
11. Conclusion
It is respectfully recommended that Boghosian Allen LLP be appointed as the Integrity
Commissioner for the Municipality of Clarington for the term ending November 14, 20 30,
subject to the Region appointing same.
Staff Contact: June Gallagher, Municipal Clerk, 902-623-3379 ext. 2102 or
jgallagher@clarington.net.
Attachments:
Attachment 1 – By-law to Appoint an Integrity Commissioner
Interested Parties:
The following interested parties will be notified of Council's decision:
Alexander Harras, Regional Clerk/Director of Legislative Services, Region of Durham
Principles Integrity
Boghosian Allen LLP
Attachment 1 to
Report LGS-021-26
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Coordinator at 905-623-3379 ext. 2131.
The Corporation of the Municipality of Clarington
By-law 2026-XXX
Being a by-law to repeal By-law 2022-039 and to appoint an
Integrity Commissioner for the Municipality of Clarington for the
Council Term of 2027-2030.
Whereas pursuant to Part V.1 of the Municipal Act, 2001 S.O. c. 25, as amended, a
municipality is authorized to appoint an Integrity Commissioner who reports to Council
and who is responsible for performing, in an independent manner, the functions
assigned by the municipality;
And Whereas Sections 223.4 to 223.8 of the Municipal Act, 2001 provide s that an
Integrity Commissioner has certain powers and protections during investigations;
And Whereas the Municipality of Clarington Council has established a Code of Conduct
for Members of Council;
And Whereas the Municipality of Clarington deems it necessary to appoint an Integrity
Commissioner to administer the Code of Conduct;
Now therefore the Council of the Municipality of Clarington enacts as follows:
1. That the Deputy CAO/Solicitor be authorized to execute, on behalf of the
Municipality of Clarington, an agreement to appoint Boghosian Allen LLP as
Clarington’s Integrity Commissioner and also to provide the required services for
Clarington’s Integrity Commissioner on such terms and conditions as included in
the Regional of Durham’s Integrity Commissioner selection process, and such
other terms and conditions as may be required by the Municipality of Clarington
to give effect to the Agreement.
2. That the services to be provided by Boghosian Allen LLP shall include the
services enumerated in subsection 223.3(1) of the Municipal Act, 2001.
Attachment 1 to
Report LGS-021-26
3. That Boghosian Allen LLP be appointed for a term from the date of November
15, 2026, to the end of the term of Clarington Council, November 14, 2030.
4. That By-law 2022-039, appointing the previous Integrity Commissioner,
Principles Integrity, be repealed effective November 14, 2026.
Passed in Open Council this XXX day of XXX, 2026.
_____________________________________
Adrian Foster, Mayor
_____________________________________
June Gallagher, Municipal Clerk
By signing this by-law on MMMM NN, YYYY, Mayor Adrian Foster will not exercise the
power to veto this by-law.