Integrity commissioner report indicates “quiet” year for complaints

By Sharon Harrison
The County’s integrity commissioner, David Boghosian, provided his annual report at last week’s council meeting, which covers the period Feb. 11, 2025 through Feb. 11, 2026, in what was Boghosian’s first full year as commissioner.

David Boghosian

He described it as a quiet year with just a few items to address, stating that, “This council has been good in my opinion in seeking advice, probably more so than a lot of other municipalities”.

An update on council code of conduct was also discussed at the meeting as a related issue, and that story can be found by clicking here.

Speaking to complaints and investigations, Boghosian said he received and investigated three complaints. Those complaints were filed by several residents with each regarding an alleged, indirect conflict of interest and improper use of influence on the part of a member of council.

“All three complaints concerned the same subject-matter, although they were received at different times,” he said, adding that the complaints were all summarily dismissed without formal reports to council.

No noted that no further complaints have come since the report, and there are no current complaints being investigated.

When it comes to requests for advice, he said he fielded a total of 11 requests for advice from members of council during the reporting period on both municipal conflict of interest and code of conduct matters.

“The majority of those had to do with MCIA (municipal conflict of interest act) or municipal conflict of interest issues, and there were a couple of code of conduct enquiries.”

“Nine were concerning potential conflicts of interest situations related to specific matters that were to be considered by council, and two relating to potential code of conduct violation issues.”

Boghosian said he also fielded a number of requests for advice from members of the public.

“I also received quite a few enquiries from members of the public, nine to be exact, which I regard to be quite a few from a municipality this size, none of them resulted in complaints,” he shared. “And I’m happy to say that in a conversation ranging from five to 15 minutes, no complaints were forthcoming from any of those enquiries.”

He explained those enquiries wished to know whether certain conduct they had observed constituted a potential MCIA or code of conduct violation.

He further noted that members of council received a code of conduct and MCIA training session on May 6, 2025.

“I provided training to council and recommend that we do further training very early in the new term of council, especially for the new councillors,” he said.

“There will likely be a new code of conduct governing your actions and that of the new members. Bill 9 passed by provincial government that adds some, what I regard as gimmicky provisions, as I don’t think there will ever be a councillor removed based on the hoops that have to be jumped through, no matter how egregious the conduct has been.”

Aside from that, he explained how there is a provision that by regulation the lieutenant governor and council can proclaim a new code of conduct province-wide that will govern all municipalities.

“It will replace all of the individual codes currently in place in the 440 or so municipalities in Ontario, so there will definitely need to be training on that new code.“

Councillor John Hirsch asked the integrity commissioner if he had any sense what the new provincial code of conduct will look like in terms of the points Mr. Allen (see related story) has brought forward concerning enforceability of requirements.

Boghosian said, he can’t say as he doesn’t know.

“The City of Toronto code and the City of Hamilton code has a broader definition of conflict of interest, or what they call, disqualifying interest than just pecuniary interest in the municipal conflict of interest act, that do cover possibly a lot of the ground that Mr. Allen was talking about,“ Boghosian shared. “Whether that will see its way into that province-wide code, I’m not sure. “

But he added that it does tend to generate a lot of code of conduct complaints.

“As the integrity commissioner for the city of Hamilton, I see first-hand the broader definition; disqualifying interests can be a source of increased number of complaints.“

Councillor Kate MacNaughton asked how to remove some of the ambiguity and harden some of the language.

“How do we create a strong enough language that there is a mechanism for compliance, not just Prince Edward County interest?”

Unfamiliar with the complaints process, councillor Brad Nieman asked if a member of the public enquires about a certain councillor, does that councillor get notified.

Explaining the process, Boghosian said if a complaint is received, and on its face it doesn’t meet the test of any code violation, he will summarily dismiss it.

“If there is some merit to it, reasonable grounds, at that point, the complaint is shared anonymously because we don’t reveal the name of the complainant if it’s a member of the public.”

The complaint is shared with the member of council and they are invited to give a response which is considered, and there maybe more investigation.

“Often, I will look into things preliminarily to satisfy myself that there is something there, I will also share my additional investigation with them [the councillor]. And there is plenty of scope for providing your input before a report is generated.”

The 2026 integrity commissioner’s annual report discussed at the June 23 council meeting, can be found on the corresponding agenda item on the County’s website, along with the meeting recording.