Code of Conduct


The Director and Employee Code of Conduct Directive provides general guidance on the standards of conduct expected of Directors and Employees of the Nunavut Development Corporation and its subsidiary companies.

The Nunavut Development Corporation, recognizing the need for a resource to provide clear interpretation of its standards of business conduct and guidelines for conflict of interest, the Corporation has established the Corporate Secretary as the Code of Conduct Advisor.

The Corporate Secretary, as the Code of Conduct Advisor, reports directly to the Corporation’s Board of Directors providing expert advice to Directors and Employees on code of conduct and conflict of interest matters that they may encounter when fulfilling their respective responsibilities.

The fundamental relationship between Director and/or Employee and the Nunavut Development Corporation must be one of trust; essential to trust is a commitment to honesty and openness.

Compliance with Law

The Nunavut Development Corporation’s Directors and Employees shall comply with all applicable provisions of Territorial, Provincial and Federal laws and regulations in jurisdictions in which the Corporation operates.

No one in the Nunavut Development Corporation shall knowingly commit or condone an illegal act or instruct another Employee, Partner or Contractor to do so.

Employees are expected to be sufficiently familiar with any legislation that applies to their work, to recognize potential liabilities and to know when to seek legal advice. If in doubt, ask for clarification from the Nunavut Development Corporation’s legal counsel.

No Director or Employee shall create or condone the creation of a false record. No Director or Employee shall destroy or condone the destruction of a record except in accordance with the Corporation’s Policies.

Directors and Employees must not engage in or give the appearance of being engaged in any illegal or improper conduct that is in violation of this code.

Conflict of Interest

Directors and Employees will perform their duties conscientiously and will not put themselves in a position in which their private interests and those of the Nunavut Development Corporation might be or perceived to be in a conflict.

A Director or Employee has an actual conflict of interest when the Director or Employee is performing a duty or function of the position and in the performance of that duty or function has the opportunity to further his or her private interests.

The Government of Nunavut’s Conflict of Interest Legislation applies to the Nunavut Development Corporation, its subsidiaries and divisions.

There is an apparent conflict of interest when a reasonably well-informed person could perceive that a Director’s or Employee’s ability to perform a duty or function of the position was or will be affected by the Director’s or Employee’s private interests.

Every Director and Employee must avoid any situation in which there is an actual or apparent conflict of interest that could interfere or could be perceived to interfere with the Employee’s or Director’s judgment in making decisions in the Nunavut Development Corporation’s best interests.

Every Director and Employee shall disclose all circumstances that constitute an actual or apparent conflict of interest. Disclosure shall be made, in the case of Directors, to the Chairperson of the Corporation, and in thecase of Employees, to the Corporate Secretary.

Some conflicts are quite clear, but others are less obvious. The Nunavut Development Corporation recognizes that its Directors and Employees have perfectly legitimate outside interests; however, there may also be situations which could be perceived as a conflict of interest no matter how innocent the intentions of the Employee or Director.

The following are three examples of circumstances where a Director’s or Employee’s private interests would be in conflict with the interests of the Nunavut Development Corporation:

  • An Employee who is responsible for awarding a contract is a partner in a firm that has tendered a submission
  • An Employee responsible for hiring is involved in the hiring process where an immediate relative has applied for employment
  • A Director who is aware of a significant investment proposal between the Nunavut Development Corporation and a Nunavut company personally invests in the company before the investment is announced publicly

Directors and employees who find themselves in a conflict of interest must disclose the conflict and abstain from voting or other actions that will impact the outcome of the activity or business transaction. Full disclosure enables Directors and Employees to resolve unclear situations and gives an opportunity to dispose of or appropriately address conflicting interests before any difficulty can arise.

Where necessary, an Employee or Director may refer an individual situation to the Nunavut Development Corporation’s Code of Conduct Advisor who may recommend actions needed to eliminate or address a conflict of interest.

The following provides a more detailed discussion of circumstances where a conflict of interest could arise and how the Nunavut Development Corporation expects its Directors and Employees to behave.

Outside Business Interests

“Business activity” refers to ownership, participation in decision-making as a member of a board of directors, or engagement as an advisor or consultant, or as an active member of staff in any position.

Employees should declare their outside business activities at the time of engagement and are required to limit outside business activities to avoid any conflicts of interest or other breaches of the provisions of the Code. Notwithstanding any outside business activities, Employees are required to act in the best interest of the Nunavut Development Corporation.

No Employee or Director should hold a substantial private interest, directly or indirectly through a relative, friend or associate or hold or accept a position as an officer or director in an entity where by virtue of his or her position with the Nunavut Development Corporation the Director or Employee could in any way benefit the entity by influencing the decisions of the Corporation.

Confidential Information

A Director or Employee should at all times maintain the confidentiality of all confidential information and all records of the Nunavut Development Corporation and must not make use of or reveal such information or records except in the course of performance of their duties or unless the documents or information become a matter of general public knowledge.

Similarly, Directors or Employees may not use confidential information obtained through their association or employment with the Nunavut Development Corporation to further their private interests or the private interests their friends or relatives.

A Director or Employee using the Nunavut Development Corporation’s computer data base or electronic mail system will be expected to comply with any internal policies and procedures that guide the storage, use and transmission of information through this medium.

Outside Employment

The Corporation’s Employees may hold outside jobs or engage in modest self-employment activities on their own time, using their own resources and in a manner not adversely affecting their performance or objectivity for the Corporation.

However no Employee may accept work with a competitor or with any entity that could lead to a conflict of interest or situation prejudicial to the Corporation’s interests.

Entertainment, Gifts and Benefits

In this discussion, “gifts or benefits” include cash, secret commissions and any other benefit whether physical or intangible such as plane tickets, accommodation packages or offers of service on a reduced fee basis.

It is essential to efficient business practices that all those who do business with the Corporation, as contractors or customers, have access to the Corporation on equal terms.

Directors and Employees and their associates should not accept entertainment, gifts or benefits which grant or appear to grant preferential treatment to a potential or actual contractor of the Corporation. Any entity offering such inducements must cease the practice; a business relationship with the Corporation will be conditional on compliance with this Code.

Similarly, no Director or Employee may offer entertainment, gifts or benefits in order to secure preferential treatment for the Corporation.

Inappropriate gifts that are received by a Director or Employee should be returned to the donor and may be accompanied by a copy of this Code.

Criteria to guide your judgment on the receiving and giving of gifts include:

  • The market value of the exchange must not exceed $250.
  • The exchange must not create an obligation now or in the future.
  • The exchange must be justifiable on an individual’s expense claim if the Employee or Director offers rather than receives it.

Business Relations with Contractors

The Corporation will deal fairly and openly with all its Contractors and will facilitate access to its business by all entities provided conditions of quality, reliability and competitiveness are met.

The Government of Nunavut’s Nunavummi Nangminiqaqtunik Ikajuuti Policy (NNI) and the Corporation’s Contracting Policy apply to all contracting activity of the Corporation, its subsidiaries and divisions.

Environment and Safety

Environmental protection is a fundamental Nunavut Development Corporation value; every Director or Employee has a role in ensuring the Corporation’s operations comply with environmental legislation and standards.

Safety must be everyone’s concern. The Corporation is committed to providing all Employees a safe, healthful, and harassment-free workplace and to ensuring safe and respectful work practices and conditions.

Management and Directors have both a legal and a moral responsibility for safety and protection of the environment and every manager has a specific obligation in this respect.

Every employee has a personal obligation to take all prudent precautions in every activity, not just to ensure personal safety, but also to avoid creating any danger to others or demonstrating behavior which can be reasonably construed as discrimination or harassment.

Use of Corporation Property

The Corporation’s assets must not be misappropriated for personal use by Directors or Employees.

Directors and Employees are entrusted with the care, management and cost-effective use of the Corporation’s property and should not make significant use of these resources for their own personal benefit or purposes.

Director’s and Employees should ensure that all Corporate property assigned to them is maintained in good condition and should be able to account for such property.

Directors and Employees may not dispose of the Corporation’s property except in accordance with the Corporation’s Capital Asset Administration Policy.

Patents and Discoveries

Employees are often engaged in various forms of research or problem solving for the Corporation. The product of their efforts produced within the scope of their employment belongs to the Nunavut Development Corporation whether the product was concluded while actually at work or not.

Such products include but are not limited to technical processes, pattern designs, casts or dies, and reports or articles and any other form of innovation or development.

Patents, rights or copyright, as appropriate, must be assigned by Employees to the Corporation.

Political Participation

Directors and Employees are encouraged to participate fully as private citizens in the democratic process at any level including campaigning in elections and running for or holding public office.

However Directors and Employees engaging in the political process should do so on their own time and must take due care to separate their personal activities from their association with the Corporation.


The Corporation is determined to behave and to be perceived as an ethical Corporation. Each Director and Employee must adhere to the standards as described in this code of conduct and to the standards set out in applicable policies, guidelines or legislation.

An Employee’s failure to adhere to these standards could lead to disciplinary action up to and including dismissal.

A Director’s failure to adhere to these standards could result in a recommendation for removal from office.

To demonstrate our determination and commitment to this undertaking all Directors of the Nunavut Development Corporation, its subsidiaries, Headquarters staff, Senior Sales Division staff and the subsidiary General Managers are required to sign a formal Declaration and file it with the Corporation’s Corporate Secretary.

Honesty, Trust and Openness are essential values of our business success. Any Director or Employee who knows or suspects that this Code of Conduct has been or is likely to be breached has a responsibility to report it.

Where to Seek Clarification

A Director or Employee who requires advice on a particular Code of Conduct matter or suspect improper activities should seek clarification from the Code of Conduct Advisor.

All disclosures to the Code of Conduct Advisor will be kept strictly confidential unless, in the sole opinion of the Advisor, the matter disclosed constitutes an actual or potential threat of serious harm to the Nunavut Development Corporation, its employees, agents or the general public.