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Management Response and Action Plan - Evaluation of the Compliance Function

Background

In December 2023, the Office of the Commissioner of Lobbying (OCL) retained the services of Samson & Associates CPA/Consulting Inc. (Samson) to conduct an evaluation of the Office’s compliance function as it relates to the OCL’s obligations under the Lobbying Act. The objectives of the evaluation focused on the Compliance Directorate’s activities related to:

  • The processes, tools, guidance documents and procedures in place to support the compliance function;
  • The documented approach for performing activities in a consistent, accountable, and repeatable manner; and
  • The capacity of the program to meet its objective of fulfilling the purpose of the Lobbying Act.

Findings and Conclusions of the Report

The findings of the final report of the Evaluation of the Compliance Function state that:

  1. the current staffing situation is adversely affecting efficiency and timeliness; and
  2. elements are in place for the compliance function to be efficient.

There are no recommendations relating to the Compliance’s Directorate efficiency arising from the evaluation. The Office of the Commissioner of Lobbying (OCL) is in agreement with the findings and conclusions of the report and provides the following response to the conclusions:

Conclusions on findings Response to conclusions on findings
  1. The Compliance Function cannot be as efficient and timely as it would be if it were fully staffed.
Efforts to recruit, retain and train personnel in the Compliance Directorate will continue to be a top priority for management as stated in the 2024-2026 Integrated Business and Human Resources Plan.
  1. The findings suggest that the processes and culture of OCL’s Compliance Function are contributing to efficiency and timeliness. The elements are in place to help ensure that the processes are defined, understood, consistent, and repeatable. This provides a solid base for the Function to continue to build on.

    The Function’s capacity [when fully staffed] appears to be sufficient for its normal, steady state volumes of activity.

Planned continuous improvements in the compliance processes, procedures, guidance documents, other tools and in the case management system, will further enhance the efficiency and timeliness of the OCL’s compliance function. These refinements will also ensure increased ability to deal with additional compliance requirements.
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