Principles & Policies for Managing Human Resources

3.2.1 Conflict Of Interest


The Manitoba government supports the rights of employees to be involved in community projects and activities as citizens of the community. This is balanced with the recognition that employees participate in government activities including making decisions affecting Manitobans, and have knowledge of a wide range of confidential information. Real, apparent or potential conflicts of interest may reduce public trust and confidence in the integrity and impartiality of government.

Employees are expected to place the public interest first in carrying out their duties. This involves avoiding or effectively resolving conflict of interest situations where private or personal interests improperly influence, could reasonably be perceived to improperly influence, or could reasonably be foreseen to improperly influence, the performance of their duties and responsibilities. Ultimately, these situations must be resolved in favour of the public interest.



This policy applies to all Manitoba government employees, including, but not limited to, regular, term, technical, departmental, and casual employees, as well as students, contracted staff and volunteers or those on a practicum placement.

An employee must not directly or indirectly:

  • Place themselves in a situation in any official matter where there is a private or personal interest where they cannot be objective in their actions or decisions.
  • Undertake outside employment, a business transaction or other private arrangement for personal profit or have any financial or other personal interest that is in conflict with the performance of their duties.
  • Seek or receive personal or private gain by granting preferential treatment to any persons while performing their duties.
  • Seek or accept personal or private gain from the use of information acquired during the course of their duties that is based upon confidential or non-public information.

    Note: The Oath of Office requires that employees, without due authority, refrain from disclosing any information, in any form, which may come to them by reason of their employment in the Manitoba government. The obligations of the Oath of Office apply throughout employment with the government of Manitoba and continue to apply after the employment relationship ends.

  • Use or permit the use of government property to promote or serve their personal or private interests, unless they are authorized to do so.

  • Solicit or accept fees, gifts or other benefits, that are connected directly or indirectly with the performance of their public service duties, from any individual, organization or corporation, other than:
    • The normal exchange of gifts among friends;
    • The normal exchange of hospitality between persons doing business together;
    • Tokens exchanged as part of protocol;
    • The normal presentation of gifts to persons participating in public function

    Any gift or benefit accepted must be of nominal value and must not create an obligation or perceived obligation.

For each of the above conflict of interest situations, an employee must consider if their private or personal interest:

  1. improperly influences the performance of their official duties and responsibilities
  2. could be reasonably perceived to improperly influence the performance of their official duties and responsibilities
  3. could reasonably be foreseen to improperly influence the performance of their official duties and responsibilities



Should an employee suspect they are, may be reasonably perceived to be, or may reasonably foresee being in a conflict of interest situation, they must immediately initiate the disclosure process.

Disclosure is a confidential procedure to protect both the employee and the employer from unfair or improper allegations of conflict of interest. It requires an employee who suspects they might be reasonably perceived to be, or might reasonably foresee being, in a conflict of interest to complete the Employee Conflict of Interest Declaration form, for his or her Deputy Minister or designate. In the case of Deputy Ministers, disclosures are made to the Clerk of the Executive Council.

The employee may be asked to provide additional information to determine if a conflict of interest exists. Once the Deputy Minister or designate reaches a decision, an employee is advised if a conflict of interest exists and if so, is given direction on how to resolve the conflict of interest.

Should an employee disagree with the decision, they can appeal the decision to the Deputy Minister or designate of the department. If the employee disagrees with the Deputy Minister or designate's decision, an appeal can then be filed with the Civil Service Commission Board as defined under Section 4(1) of The Civil Service Act. During this appeal, the employee has the option of having a representative present. The Civil Service Commission Board’s decision is final.

Failure to disclose and/or address a conflict of interest appropriately may result in disciplinary action up to and including dismissal.

Where an employee believes he or she was unfairly disciplined for a breach of the conflict of interest policy, there is recourse in the grievance procedures of their collective agreement or as set out in The Civil Service Act and the Conditions of Employment Regulation.




  • Review the interaction between their duties and responsibilities and their private and personal interests on a regular basis to ensure that they do not conflict.
  • Ensure new or changed duties and responsibilities, organizational relationships and/or responsibilities, or private or personal interest situations are dealt with in accordance with this policy.
  • Immediately initiate the disclosure process should they suspect they are, may be reasonably perceived to be, or may reasonably foresee being, in a conflict of interest situation.
  • Ensure awareness and compliance with this policy and any other legislation or policies applicable to their role, department or agency for additional conflict of interest provisions (e.g. The Legislative Assembly and Executive Council Conflict of Interest Act, department specific guidelines (e.g. Justice), Oath of Office).


  • Review disclosures and document initial assessment and comments for consideration.
  • Request additional information from the employee if required.
  • Discuss resolution with the employee.
  • Investigate alleged breaches of this policy.

Deputy Minister or Designate

  • Assess disclosures and determine if a conflict of interest exists.
  • Determine appropriate resolution to avoid a conflict of interest.
  • Ensure resolution and appropriate action has taken place.
  • On at least an annual basis, communicate to employees their responsibility to disclose conflict of interest situations in accordance with policy and department guidelines.
  • Establish additional guidelines if required to address department specific disclosure requirements.

Clerk of the Executive Council

  • In the case of Deputy Ministers:
    • Assess disclosures and determine if a conflict of interest exists.
    • Determine appropriate resolution to avoid a conflict of interest.
    • Ensure resolution and appropriate action has taken place.

Human Resources (Civil Service Commission)

  • Provide advice and guidance to management and employees on this policy.
  • Assist management in discussing specific situations with an employee.
  • Investigate (with management) alleged breaches of this policy.

Labour Relations Division, Treasury Board Secretariat

  • Advise regarding the interpretation, application and administration of this policy.



This policy should be read in the context of the following and any other applicable legislation and policies:



Private or personal interests - actual/potential financial gain/loss or actual/potential favour or prejudice that can bring benefit to us as individuals or to others, including a spouse, partner, child, relative, friend, past or present business associate, or organization.

Government property - includes but is not limited to information not generally available to the public, government facilities (boardrooms, office space, office address, etc.), vehicles, equipment (computers, photocopy machine, fax machine, boats, motors or other field equipment, etc.), material (paper, supplies, etc.), or intangible government property (such as government working time).



  • Cabinet Minute #16, February 1, 1984, as amended in 1996, 2007, 2015
  • June 13, 2012 Condition of Employment Regulations

Effective Date: January 19, 2015
Revised effective: May 22, 2019


Civil Service Commission

Additional information:

Civil Service Commission
Phone: 204-945-2332



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