Mary Dawson Office of the Conflict of Interest and Ethics Commissioner Parliament of Canada 66 Slater Street, 22nd Floor Ottawa, Ontario Dear Ms Dawson, I am writing to you about a possible conflict of interest involving Minister of Labour Lisa Raitt. Electronic flight records show that the Raitt, and her Chief of Staff Douglas Smith, were given complimentary upgrades to business class, approved personally by Duncan Dee, Air Canada's Chief Operating Officer. I also would like to draw your attention to the timeline around these gifts being given and ongoing labour negotiations between Air Canada and their Flight Attendants. Ms. Raitt was given a free upgrade on September 25, 2011, just days after threatening Air Canada employees with back-to-work legislation. Raitt's Chief of Staff was then provided with a free upgrade courtesy of Mr. Dee on October 10, 2011 - the same week Minister Raitt blocked job action at Air Canada by asking for a review by the Canada Industrial Relations Board. I believe these actions possibly breached sections four and seven of the Conflict of Interest Act: Section 4; Conflict of Interest: For the purposes of this Act, a public office holder is in a conflict of interest when he or she exercises an official power, duty or function that provides an opportunity to further his or her private interests or those of his or her relatives or friends or to improperly further another person's private interests. Section 7; Preferential treatment: No public office holder shall, in the exercise of an official power, duty or function, give preferential treatment to any person or organization based on the identity of the person or organization that represents the first-mentioned person or organization. Furthermore, Sections 11, 12 and 23 of the Act specifically prohibit a public figure from accepting gifts and travel from a person or organization of influence. Ms Raitt's upgrade for a short, one-hour flight is valued at almost $450.00. Here again, I believe the Minister of Labour has possibly put herself in violation and I draw your attention to the following three sections: Section 11; Gifts and other advantages: No public office holder or member of his or her family shall accept any gift or other advantage, including from a trust, that might reasonably be seen to have been given to influence the public office holder in the exercise of an official power, duty or function. Section 12; Travel: No minister of the Crown, minister of state or parliamentary secretary, no member of his or her family and no ministerial adviser or ministerial staff shall accept travel on non-commercial chartered or private aircraft for any purpose unless required in his or her capacity as a public office holder or in exceptional circumstances or with the prior approval of the Commissioner. Section 23; Disclosure of gifts: If the total value of all gifts or other advantages accepted by a reporting public office holder or a member of his or her family exceeds $200 from any one source other than relatives and friends in a 12month period, the reporting public office holder shall disclose the gifts or other advantages to the Commissioner within 30 days after the day on which the value exceeds $200. To fairly deal with a labour dispute like this one, it is essential the Minister of Labour maintain a position of neutrality that permits her to play the role of honest broker. I believe that if proven true, accepting free gifts from Air Canada's Chief Operating Officer would compromise the Labour Minister's ability to mediate this dispute without bias. I believe that it falls within your mandate to look into these allegations and ask that you open an investigation into these possible breaches of the Conflict of Interest Act. Sincerely, (original signed by) Yvon Godin, MP (Acadie-Bathurst) Official Opposition Critic for Labour New Democratic Party of Canada CI- Y5=Ifi? FT I IiiF--1Ciiji ZATIZ I-I QEQ I EA FZ V-AY I Tii_1i-.-A_