How does CCIC deal with organizations that are not in compliance?

The overall objective of the ethics program is to promote ethical practice through reflection, discussion and appropriate action.  The CCIC Code of Ethics and Operational Standards is the guiding framework for CCIC and its members.  As such it includes a set of basic ethical principles that organizations accept and promote, and a set of standards of practice that provide guidance on implementing the principles and compliance procedures.  The approach is to guide organizations to improve, not to punish them if they are below standard.

When organizations first join the Council, it is often the case that they do not yet fully comply with all the standards.  They may not have a conflict of interest policy, for example, or they may not have mutually signed partnership agreements.  The purpose of the process of self-assessment and compliance is for organizations to reflect on their policies, procedures and practices in comparison with the standards and determine areas that meet the standard, and areas that need to be strengthened or changed.  There is a commitment made by all new members that they will work to comply with all the standards.  A three-year timeframe is provided to allow organizations to undertake the steps necessary to meet the standards of practice.  CCIC has resources to help guide organizations to interpret the Principles and Standards so that they can implement them. 

Once organizations are members, they undertake a renewal of compliance process every three years.  This allows organizations the opportunity to again reflect on their practices, update or add new policies and procedures, and discuss any issues of ethical practice.  This process sometimes identifies areas of weakness that were not noticed in previous discussions and reflections.  CCIC encourages organizations to notify the Council when they identify such areas of weakness.  Within reason, the Council allows a grace period for the organization to undertake the needed improvements.  It does not penalize members when such areas of “non-compliance” are identified by the organization. 

The current version of the Code of Ethics and Operational Standards was approved by CCIC members at the Council's 2009 Annual General Meeting. It represents a significant updating and revision of the previous Code, and contains a number of new standards. So, rather than simply undergoing a renewal of compliance, between now and 2013 CCIC members will be required to once again complete a full self-assessment of their status of compliance. A sample of their completed self-assessment forms will be reviewed by the CCIC Secretariat to determine if there are any particular questions or issues arising. However, the Secretariat does not have the resources to review all the self-assessment forms in detail. As always, the onus for compliance rests with member organizations themselves.

From time to time CCIC is approached, through its registration of concern procedure, with a concern that an organization is not in compliance with certain operational standards.  Again, the process is one of discussion with the organization, determination of whether its practice is appropriate for the compliance requirements, and provision of guidance, if necessary, for areas of improvement.  The understanding exists with members that they will undertake the steps necessary to ensure that they remain in compliance with the Code.  A timeframe is set out for the organization to fulfill this requirement.  If the organization is not willing to satisfy the expectation, the CCIC Board of Directors is notified that the member has not fulfilled the membership requirement. 

Therefore, the answer to this question is that it all depends on the circumstances surrounding the “non-compliance”.  The CCIC Code of Ethics and Operational Standards does not have clear rules that say exactly how organizations must do something.  Interpretation and discussion are often needed.  The priority of the Council is to provide space for such discussion and guidance for interpretation so that organizations can reach compliance.  Only if it is evident that there is a clear situation of non-compliance (i.e. the organization has not completed the self-assessment process or has not responded to a concern) and it is evident that the organization is uncooperative, would the Council determine that the organization has not fulfilled its membership requirement of compliance.  The organization’s membership would be revoked.  Yes, this has happened.