Deloitte Final English
-
Upload
ipoliticsca -
Category
Documents
-
view
225 -
download
0
Transcript of Deloitte Final English
-
8/7/2019 Deloitte Final English
1/24
Review of Closed
Operational FilesOffice of Public SectorIntegrity Commissioner
March 31, 2011Confidential
-
8/7/2019 Deloitte Final English
2/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files i
Table of contents
1 Introduction and Background .................................................................................................................. 11.1 Introduction and Objective ......................................................................................................... 11.2 Background................................................................................................................................ 11.3 Mandate ..................................................................................................................................... 1
2 Executive Summary ................................................................................................................................ 32.1 Overall results of file review ....................................................................................................... 32.2 Overall summary of issues identified ......................................................................................... 3
3 Scope of Review ..................................................................................................................................... 44 Our understanding of the types of complaints and the OPSIC process for handling complaints .......... 5
4.1 Disclosure of alleged wrongdoing by public servants................................................................ 54.2 Disclosure of alleged wrongdoing pursuant to Section 33 of the PSPDA ................................. 64.3 Complaints of alleged reprisal ................................................................................................... 7
5 Discussions of Findings .......................................................................................................................... 95.1.1 Files covered by our review ................................................................................................ 95.1.2 Completeness of files .......................................................................................................... 9
5.2 Distribution of files reviewed ...................................................................................................... 95.3 Approach and methodology ....................................................................................................... 9
5.3.1 Applicable Act ................................................................................................................... 105.3.2 Other applicable guidelines, rules and regulations ........................................................... 10
5.4 Overall results of our review .................................................................................................... 105.4.1 Results by type of file ........................................................................................................ 115.4.2 Result by fiscal year .......................................................................................................... 12
5.5 Discussion of types of issues identified ................................................................................... 135.5.1 Not all issues reported to OPSIC were dealt with ............................................................. 13 5.5.2 Lack of documentation to support the conclusions ........................................................... 135.5.3 Lack of analysis to support the conclusions ..................................................................... 135.5.4 No admissibility analysis ................................................................................................... 135.5.5 New information provided to OPSIC and file was not re-evaluated .................................. 14
-
8/7/2019 Deloitte Final English
3/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files ii
5.5.6 Decision letter signed by Registrar ................................................................................... 145.5.7 Other types of issues ........................................................................................................ 14
Appendix A List of OPSIC Closed Operational Files Reviewed .............................................................. 15
-
8/7/2019 Deloitte Final English
4/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files iii
Confidential
March 31, 2011
Mr. Mario DionInterim Public Sector Integrity CommissionerOffice of Public Sector Integrity Commissioner60 Queen Street, 7th Floor
Ottawa, ON K1P 5Y7
Subject: Review of closed operational files
Dear Mr. Dion:
Attached is our report setting out the findings from our review.
Our findings are based on procedures undertaken as described in Section 3 of this report and are subject tothe restrictions in scope as set out therein.
Should you have any questions or concerns, please do not hesitate to contact me at 613-751-5378.
Yours very truly,
Original report signed
Gary Timm, CAIFA, CFEPartner, Financial Advisory
Deloitte & Touche LLP
Enclosure
Deloitte & Touche LLP100 Queen Street
Suite 800Ottawa ON K1P 5T8
Tel: 613-751-5378Fax: 613-563-2244www.deloitte.ca
-
8/7/2019 Deloitte Final English
5/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 1
1Introduction and background
1.1 Introduction and objective
Deloitte & Touche LLP (Deloitte) was retained by the Office of the Public Sector Integrity Commissionerof Canada (OPSIC) to perform a review of closed disclosure of wrongdoing and reprisal complaints filesin order to determine whether they were dealt with in a manner consistent with the requirements of thePublic Servants Disclosure Protection Act(PSDPA) and with applicable legal1, investigative andadministrative decision-making standards. The purpose of the review is to identify any possible issues orerrors in process or fact in the files in relation to the criteria as set out in Section 1.3.
1.2 Background
OPSIC has the mandate to establish a safe, confidential and independent mechanism for public servantsor members of the public to disclose potential wrongdoing in the federal public sector. It also protectspublic servants from reprisal for making such disclosures or cooperating in investigations. OPSICs goalis to enhance public confidence in our public institutions and in the integrity of public servants. In carryingout its mandate, the Commissioner is required to submit an annual report to Parliament.
On October 20, 2010, OPSIC announced that Christine Ouimet, the Public Sector Integrity Commissioner,retired from Public Service, effective October 18, 2010.
On December 9, 2010, the Auditor General (AG) of Canada issued a report related to a performanceaudit of OPSIC. With regard to the performance of PSICs mandated function, the AG reported thefollowing:
In our view, the allegations against the Commissioner concerning the improperperformance of her mandated functions are founded. During the period covered by ouraudit, procedures for conducting investigations were not finalized or implemented. Wealso found that, in many cases, decisions to refuse to investigate, or to dismissdisclosures of wrongdoing and complaints of reprisal were not supported by either thenature of work performed, the documentation on file, or both. It is also our viewthat decisions by the Commissioner to refuse to investigate certain complaints of reprisalon the basis that she could not conclude that an act of reprisal had occurred extendedbeyond her responsibilities under the PSDPA. Again, we considered information gatheredfrom multiple sources in the course of our audit in arriving at this conclusion.
Mr. Mario Dion was appointed Interim Commissioner in December 2010. Mr. Dion initiated acomprehensive third party review of all closed files from the inception of OPSIC in 2007 to December 20,
2010. Following a competitive procurement process, Deloitte was retained to undertake the third partyreview.
1.3 Mandate
The Deloitte engagement consisted of a review and assessment of all closed disclosure and reprisalcomplaint files, totalling 221 files. For each file, Deloitte was asked to review and assess the followingfactors:
1 Our work and the resulting report do not constitute a legal opinion regarding the PSPDA, nor do they represent such an opinion inany way.
-
8/7/2019 Deloitte Final English
6/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 2
1. Determine the issues and allegations identified (reported to PSIC) in the disclosure or reprisalcomplaint;
2. Assess whether the analysis conducted by PSIC addresses all relevant issues and allegations;
3. Assess whether the analysis conducted by PSIC provides a rationale or reasons for therecommendations in accordance with the requirements of the PSPDA;
4. Assess whether the decision rendered addresses the relevant issues and allegations;
5. Assess whether the decision rendered meets the requirements of the PSDPA; and
6. Assess whether there is sufficient documentation on file to support the analysis,recommendations and the decision of the Commissioner.
OPSIC requested that we conduct a process review and assess closed files in relation to the six specificquestions or factors, as noted above. We were not requested by OPSIC to review and assess thespecifics of the case analysis work performed and the appropriateness, adequacy and completeness ofthe investigative steps undertaken by OPSIC personnel.
We understand that OPSIC has retained the services of a Special Advisor to provide the InterimCommissioner with recommendations regarding possible corrective measures for any file where an issuerelating to one or more of the factors above is identified.
-
8/7/2019 Deloitte Final English
7/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 3
2Executive summary
2.1 Overall results of file review
Based on our review of the 221 closed operational files, we identified 70 files that have issues in relationto the factors that were reviewed and assessed as defined in Section 1.3 of this report. We did not identifyissues in relation to the factors that were reviewed and assessed with the remaining 151 files.
Table 1: Summary of Files Reviewed, by Fiscal Year
Nature of deficiency FY2007/2008 FY2008/2009 FY2009/2010 FY2010/2011 Tota l
Issues identified 34 18 16 2 70
No issues identified 43 47 44 17 151
Total number of files 77 65 60 19 221
Percentage of files where issues
were identified44% 28% 27% 11% 32%
Number of files
2.2 Overall summary of issues identified
The following chart summarizes the types of issues identified in the files reviewed by fiscal year:
Table 2: Summary of Issues Identified, by Fiscal Year
Nature of issue FY2007/2008 FY2008/2009 FY2009/2010 FY2010/2011 Total
Not all issues reported to OPSIC
were dealth with14 5 4 2 25
Lack of documentation to support
the conclusions19 4 7 2 32
Lack of analysis to support the
conclusions12 8 10 1 31
No admissibility analysis 4 4 4 12
New information provided to OPSIC
and file was not re-evaluated4 1 5
Decision letter signed by Registrar 2 1 3
Other types of issues 1 4 1 6
Total number of issues identified 56 27 26 5 114
Total number of files where
issues were identified [1]34 18 16 2 70
Number of files where issues were identified
[1] Due to specific files containing multiple types of issues, the total number of files identified as having issues is less than thetotal number of issues identified.
-
8/7/2019 Deloitte Final English
8/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 4
3Scope of review
Our review covered the period from inception of OPSIC in 2007 to December 20, 2010 (the ReviewPeriod) and was limited to the issues described in this report. This period was selected based oninstructions from OPSIC.
Our review included 221 closed operational files as identified and provided to us by OPSIC. We havepresented a list of the specific files reviewed at Appendix A to this report.
Our procedures during the Review Period included a review of the available documentation contained inthe OPSIC closed files, as provided to us, along with processes, policies and procedures of OPSICrelevant to the issues. We have not undertaken interviews of the OPSIC personnel or third parties in
relation to these files.
In preparing the report, we specifically reviewed and/or relied upon the Public Servants DisclosureProtection Act, S.C.2005, C. 46, current to December 14, 2010, published by the Minister of Justice athttp://laws-lois.gc.ca
As previously noted, OPSIC requested that we conduct a process review and assess closed files inrelation to the six specific questions or factors, as outlined at Section 1.3 of this report. We were notrequested by OPSIC to review and assess the specifics of the case analysis work performed and of theappropriateness, adequacy and completeness of the investigative steps undertaken by OPSIC personnel.
We reserve the right, but will be under no obligation, to review this report, and if we consider it necessary,to revise our report in light of any information, which becomes known to us after the date of this report.
Our work does not constitute an audit as defined by the Canadian Institute of Chartered Accountants.Consequently, said work and the resulting report do not constitute an auditors opinion nor do theyrepresent such an opinion in any way.
-
8/7/2019 Deloitte Final English
9/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 5
4Our understanding of the types ofcomplaints and the OPSIC process
for handling complaints
In terms of complaints received by OPSIC, they include three categories:
1. Disclosure of alleged wrongdoing by public servants;
2. Disclosure of alleged wrongdoing pursuant to Section 33 of the PSPDA; and
3. Complaints of alleged reprisal.
Our understanding of each of these categories is described in the following sections.
4.1 Disclosure of alleged wrongdoing by public servants
Public Servants (as defined at Section 2 of the PSPDA) can disclose allegations of wrongdoing to OPSIC.The types of disclosures from public servants that OPSIC can investigate include the following types ofalleged wrongdoing2:
1. A contravention of any Act of Parliament or of the legislature of a province or any regulations
made under any such act;
2. A misuse of public funds or a public asset;
3. A gross mismanagement in the federal public sector;
4. An act or omission that creates a substantial and specific danger to the life, health or safety ofpersons, or to the environment, other than a danger that is inherent in the performance of theduties or functions of a public servant;
5. A serious breach of a code of conduct (established by Treasury Board or by an organization, asrequired by the PSPDA); and
6. Knowingly directing or counselling a person to commit a wrongdoing as defined in 1 to 5 above.
We understand that OPSICs review process for disclosures of alleged wrongdoing by public servants isas depicted in the following diagram.
2Public Servant Disclosure Protection Act (S.C. 2005, c. 46), section 8 wrongdoings.
-
8/7/2019 Deloitte Final English
10/24
Deloitte & Touche LLP and affiliated entiti
Although the state of the review proreview, the key processes reviewed
1. Receipt of the disclosure aOPSIC's Registrar. The disrequired to thoroughly revieanother mechanism that mi
2. Review of the admissibilityadvisor, reviews the informcould include consultationand law. A detailed admissiCommissioner, with a reco
3. Commissioner's decision file and admissibility reportinvestigation. A decision leproceed with an investigati
4.2 Disclosure of alleged
Section 33(1) of the PSPDA providwrongdoings related to the Public Sattention of OPSIC by individuals ot
The types of alleged wrongdoing thof this report (Disclosure of alleged
The distinction made at Section 33(
1. The Commissioner must ha
s. OPSIC: Review of clo
Source: OPSIC webs
cess has evolved since the inception of OPSIC, forwere as follows:
d initial assessment All disclosures are receivedloser may be contacted for clarification or additiona
w the disclosure. It is possible that the discloser willght address the issue more appropriately.
of the disclosure An analyst/investigator, with thetion presented to determine if further action is requiith subject-matter experts and research on relevant
bility report is submitted to the Commissioner, or tomendation to either proceed or to take no further a
The Commissioner or Deputy Commissioner reviewto determine if further action is needed, including latter is transmitted to the discloser indicating whethern.
rongdoing pursuant to Section 33 of th
s additional powers to OPSIC to investigate other aervice typically these are allegations of wrongdoinher than public servants.
t OPSIC can investigate are identical to those listewrongdoing by public servants).
1) of the PSPDA is that a two-part test must be met,
ve reason to believe that a wrongdoing has been co
ed operational files 6
te
he purpose of our
nd reviewed byl informationbe advised of
upport of a legalred. This reviewissues of policyhe Deputyction.
s the disclosurenching anor not OPSIC will
PSPDA
llegedg brought to the
at Section 4.2.1
namely that:
mmitted; and
-
8/7/2019 Deloitte Final English
11/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 7
2. The Commissioner must believe on reasonable grounds that the public interest requires aninvestigation.
If the above two-part test is met, we understand that OPSICs review process is identical to the processlisted at Section 4.2.1 of this report (Disclosure of alleged wrongdoing by public servants).
4.3 Complaints of alleged reprisalOPSIC has exclusive jurisdiction to investigate complaints of alleged reprisals. Current and former PublicServants (as defined at Section 2 of the PSPDA) can make a complaint to OPSIC if, because thecomplainant has made a protected disclosure or has, in good faith, cooperated to disclose allegations ofwrongdoing to OPSIC, the complainant has been subjected to alleged reprisal(s). Measures takenagainst current and former Public Servants which can represent a reprisal include the following:
1. A disciplinary measure,
2. The demotion of a public servant,
3. The termination of employment of a public servant, including, in the case of a member of theRoyal Canadian Mounted Police, a discharge or dismissal,
4. Any measure that adversely affects the employment or working conditions of the public servant;and
5. A threat to take any of the measures or directing a person to do so.
We understand that OPSICs review process for complaints of alleged reprisal for current and formerpublic servants is as depicted in the following diagram.
-
8/7/2019 Deloitte Final English
12/24
Deloitte & Touche LLP and affiliated entiti
Although the state of the review pro
review, the key processes reviewed
1. Receipt of the complaints oreprisal are received and reclarification or additional inf
2. Review of the admissibilityinformation to review a reprnot to deal with it. An anala recommendation to the Cshould be dealt with or not
3. Commissioner's decision
the complainant to indicatefor this decision.
s. OPSIC: Review of clo
Source: OPSIC websi
cess has evolved since the inception of OPSIC, for
were as follows:
f alleged reprisal and initial assessment All complviewed by OPSIC's Registrar. The complainant maormation required to thoroughly review the complain
of the complaint of alleged reprisal Once OPSIC hisal complaint, the Commissioner has 15 days to dest/investigator will prepare an admissibility analysisommissioner or Deputy Commissioner on whether ty OPSIC.
The Commissioner or Deputy Commissioner sends
whether they will deal with the complaint and, if not,
ed operational files 8
e
he purpose of our
ints of allegedbe contacted for
t.
as sufficientcide whether orin order to providee complaint
a written notice to
provide reason(s)
-
8/7/2019 Deloitte Final English
13/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 9
5Discussions of findings
5.1 Files subject to our review
5.1.1 Files covered by our review
Our review was limited to 221 closed operational files, as of December 10, 2010, as identified at AppendixA to this report. We have been advised by OPSIC that this list includes all files which have been closedsince the inception of OPSIC in 2007 to December 20, 2010.
Our review did not include files which had not been closed as of December 20, 2010 (i.e. files that werebeing assessed as to their admissibility and file for which investigations were being conducted by OPSIC).
5.1.2 Completeness of files
OPSIC was responsible for providing us the files to be reviewed. In order to ensure that the files werecomplete, and that we had access to all available information to review and assess the six specificquestions or factors, OPSIC representatives performed a review of electronic information contained in theOPSIC Case Management System (CMS), as well as other existing electronic information saved onOPSICs network.
Any additional information identified from a review of CMS and other electronic information was printed forour review and identified as additional information.
For cases where information appeared to be missing from the file based on the information reviewed, we
made further inquiries with OPSIC representatives in order to determine whether the information wasavailable or not before concluding on our review and assessment of the specific file.
5.2 Distribution of files reviewed
The 221 files covered by our review are categorized by file type as follows:
1. Disclosure of alleged wrongdoing by Public Servants 100 files
2. Disclosure of alleged wrongdoing pursuant to Section 33 of the PSPDA 55 files
3. Complaints of alleged reprisal 66 files
This summary of files by category may differ slightly from OPSICs categorization of these files as wehave reclassified a small number of files as a result of our review.
5.3 Approach and methodology
In order to conclude on each of the six factors to be reviewed and assessed for each of the closedoperational files, we completed the following:
1. We requested the documentation for each specific file from OPSIC, which we understandincluded all information available at OPSIC as outlined at Section 5.1.2. The majority of each ofthe files comprised a single filing folder. Some of the closed files comprised multiple filing folders,or had additional documents contained in binders, accordion files or boxes.
-
8/7/2019 Deloitte Final English
14/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 10
2. The files were reviewed and key information captured in a template specific to the type of file (i.e.,disclosures by public servants, Section 33 disclosures and complaints of reprisal). Thesetemplates were based on the relevant sections of the PSPDA. The information captured enabledthe review and assessment of the six factors outlined at Section 1.3 for each file reviewed.
3. The overall results of the individual reviews were compiled. If the review template for a filecontains a no answer to one or more of the factors #2 to 6 being reviewed, it was identified has
having an issue.
4. The issues identified were grouped by their type and nature in order to provide OPSIC with anoverall summary of issues identified and their frequency within the population of files reviewed.
5.3.1 Applicable Act
Our work was completed pursuant to the provisions of the PSDPA. We reviewed the PSPDA andobtained an understanding of specific provisions from OPSIC in order to identify which sections of thePSPDA were applicable to our review of the six specific factors. Our review of each OPSIC file wasbased on our understanding of the PSPDA.
Our work and the resulting report do not constitute a legal opinion regarding the PSPDA, nor do they
represent such an opinion in any way.
5.3.2 Other applicable guidelines, rules and regulations
Certain of the files reviewed included determination, recommendation and decisions regarding other Actsof Parliament. As an example, OPSIC may have refused to investigate an allegation of wrongdoing ifOPSIC determined that another Act of Parliament was better suited for the subject-matter of theallegations. In such cases, we have not reviewed the details of these guidelines, rules, regulations andActs of Parliament. Rather, we have reviewed the content of the file and assessed if a rationale existedfor OPSICs determination that these guidelines, rules, regulations and Acts of Parliament were bettersuited to deal with the subject-matter of the allegations.
5.4 Overall results of our review
Based on our review of the 221 closed operational files, we identified 70 files that have issues in relationto the factors that were reviewed and assessed as defined in Section 1.3 of this report. We did not identifyissues in relation to the factors that were reviewed and assessed with the remaining 151 files.
-
8/7/2019 Deloitte Final English
15/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 11
The following chart summarizes the types of issues we have identified in the files reviewed:
Table 3: Summary of Issues Identified
Nature of issueNumber of files where
issue was identified
Not all issues reported to OPSIC were dealth with 25
Lack of documentation to support the conclusions 32
Lack of analysis to support the conclusions 31
No admissibility analysis 12
New information provided to OPSIC and file was not
re-evaluated5
Decision letter signed by Registrar 3
Other types of issues 6
Total number of issues identified 114
Total number of files where issues were identified [1] 70
[1] Due to specific files containing multiple types of issues, the total number of files identified ashaving issues is less than the total number of issues identified.
We have provided OPSIC with the specifics of our findings. As previously noted, we understand thatOPSIC has retained the services of a Special Advisor to provide the Interim Commissioner withrecommendations regarding possible corrective measures for any file where one or more issues havebeen identified.
5.4.1 Results by type of file
The table below summarizes a breakdown of the results of our review of the 221 closed operational files,by type of file, separating files where issues have been identified from files where no issues wereidentified in relation to the factors that were reviewed and assessed.
Table 4: Summary of Files Reviewed, by Type of File
Disclosure from
public servant
Section 33
disclosure
Complaint of
reprisalTotal
Issues identified 27 20 23 70
No issues identified 73 35 43 151
Total 100 55 66 221
Number of files
-
8/7/2019 Deloitte Final English
16/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 12
The following chart summarizes the types of issues identified in the files reviewed by the three categoriesof files:
Table 5: Summary of Issues Identified, by Type of File
Nature of issueDisclosure from
public servant
Section 33
disclosure
Complaint of
reprisal
Total
Not all issues reported to OPSIC
were dealth with10 8 7 25
Lack of documentation to support
the conclusions13 8 11 32
Lack of analysis to support the
conclusions12 6 13 31
No admissibility analysis 8 2 2 12
New information provided to OPSIC
and file was not re-evaluated2 3 5
Decision letter signed by Registrar 1 2 3
Other types of issues 4 2 6
Total number of issues identified 48 30 36 114
Total number of files where
issues were identified [1]27 20 23 70
Number of files where issues were identified
[1] Due to specific files containing multiple types of issues, the total number of files identified as having issues is less thanthe total number of issues identified.
5.4.2 Result by fiscal year
The table below is a summary of the results of our review of the 221 closed operational file, by fiscal year(year-end date being March 31), separating files where issues have been identified from files where noissues were identified in relation to the factors that were reviewed and assessed.
Table 6: Summary of Files Reviewed, by Fiscal Year
FY2007/2008 FY2008/2009 FY2009/2010 FY2010/2011 Total
Issues identified 34 18 16 2 70
No issues identified 43 47 44 17 151
Total 77 65 60 19 221
Number of files
-
8/7/2019 Deloitte Final English
17/24
-
8/7/2019 Deloitte Final English
18/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 14
5.5.5 New information provided to OPSIC and file was not re-evaluated
We have identified five (5) instances where new or additional information was provided to OPSIC but,based on specific comments included in correspondence to the discloser or complainant or a lack thereof,it does not appear that OPSIC reviewed the additional information or re-evaluated the status of the file.
5.5.6 Decision letter signed by Registrar
We have identified three (3) instances where a decision letter was signed by the registrar. This practiceappears to be contrary to Section 24(3) and 25(1)(g) of the PSPDA.
Section 24(3) of the PSPDA states that:
If the Commissioner refuses to deal with a disclosure or to commence an investigation,he or she must inform the person who made the disclosure, or who provided theinformation referred to in section 33, as the case may be, and give reasons why he orshe did so.
And Section 25(1) of the PSPDA states that:
The Commissioner may delegate to any employee in the Office of the Public SectorIntegrity Commissioner any of his or her powers and duties under this Act, except
(g) the power in section 24 to refuse to deal with a disclosure or to commence aninvestigation, the power in that section to cease an investigation and the duty in thatsection to provide reasons;
5.5.7 Other types of issues
We have also noted instances of the following issues:
1. PSIC indicated that a matter would be referred to another agency but there is no evidence on filethat this was done.
2. File received in error and only referred to the Office of the Auditor General after seven weeks hadgone by, without notifying the discloser.
3. On two files, OPSIC did not address the question of whether OPSIC should investigate adisclosure against its own employee, or whether this should be referred to the Office of theAuditor General.
4. Lack of evidence that OPSIC notified the discloser of its decision to undertake an investigation.
5. Lack of an indication that a separate file was opened to deal with a portion of the information
received (i.e. no indication that a reprisal file was opened).
-
8/7/2019 Deloitte Final English
19/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 15
Appendix A
List of OPSIC closed operational files
reviewed
We have reviewed the following OPSIC closed operational files. The files numbers are based on thenumbering system utilized by OPSIC in their case management system.
1. PSIC-2007-D-015
2. PSIC-2007-R-016
3. PSIC-2007-R-038
4. PSIC-2007-D-064
5. PSIC-2007-S33-068
6. PSIC-2007-S33-072
7. PSIC-2007-R-078
8. PSIC-2007-S33-089
9. PSIC-2007-S33-094
10. PSIC-2007-S33-102
11. PSIC-2007-D-107
12. PSIC-2007-S33-108
13. PSIC-2007-S33-130
14. PSIC-2007-R-135
15. PSIC-2007-D-136
16. PSIC-2007-R-140
17. PSIC-2007-D-141
18. PSIC-2007-S33-145
19. PSIC-2007-R-147
20. PSIC-2007-D-149
21. PSIC-2007-R-151
22. PSIC-2007-S33-153
23. PSIC-2007-S33-155
24. PSIC-2007-R-156
25. PSIC-2007-S33-157
26. PSIC-2007-D-162
27. PSIC-2007-S33-163
28. PSIC-2007-D-164
29. PSIC-2007-D-168
30. PSIC-2007-R-172
31. PSIC-2007-D-173
32. PSIC-2007-D-175
33. PSIC-2007-D-177
34. PSIC-2007-R-178
35. PSIC-2007-R-180
36. PSIC-2007-S33-184
37. PSIC-2007-D-185
38. PSIC-2007-D-187
39. PSIC-2007-D-190
40. PSIC-2007-D-191
-
8/7/2019 Deloitte Final English
20/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 2
41. PSIC-2007-D-193
42. PSIC-2007-R-198
43. PSIC-2007-D-200
44. PSIC-2007-S33-203
45. PSIC-2007-R-204
46. PSIC-2007-R-207
47. PSIC-2008-D-208
48. PSIC-2007-D-209
49. PSIC-2007-D-210
50. PSIC-2007-R-213
51. PSIC-2007-S33-214
52. PSIC-2007-R-215
53. PSIC-2007-D-216
54. PSIC-2007-D-224
55. PSIC-2007-R-225
56. PSIC-2007-R-226
57. PSIC-2007-S33-228
58. PSIC-2007-D-240
59. PSIC-2007-A-243
60. PSIC-2007-S33-249
61. PSIC-2007-S33-251
62. PSIC-2007-R-252
63. PSIC-2007-R-260
64. PSIC-2008-D-269
65. PSIC-2007-R-271
66. PSIC-2007-D-281
67. PSIC-2007-D-282
68. PSIC-2007-D-286
69. PSIC-2007-R-287
70. PSIC-2007-D-291
71. PSIC-2007-D-296
72. PSIC-2007-A-299
73. PSIC-2007-D-305
74. PSIC-2007-R-310
75. PSIC-2007-S33-312
76. PSIC-2008-S33-325
77. PSIC-2008-S33-326
78. PSIC-2008-D-328
79. PSIC-2008-D-329
80. PSIC-2008-A-333
81. PSIC-2007-R-337
82. PSIC-2008-S33-338
83. PSIC-2008-D-345
84. PSIC-2008-D-350
85. PSIC-2008-D-351
86. PSIC-2008-D-353
87. PSIC-2008-D-354
88. PSIC-2008-D-362
89. PSIC-2007-A-366
90. PSIC-2008-D-368
91. PSIC-2008-R-370
92. PSIC-2008-S33-376
93. PSIC-2008-D-382
94. PSIC-2008-D-384
95. PSIC-2008-R-385
96. PSIC-2008-R-387
97. PSIC-2008-D-388
98. PSIC-2008-D-389
-
8/7/2019 Deloitte Final English
21/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 3
99. PSIC-2008-R-391
100. PSIC-2008-S33-398
101. PSIC-2008-R-400
102. PSIC-2008-D-403
103. PSIC-2008-S33-407
104. PSIC-2008-D-408
105. PSIC-2008-R-411
106. PSIC-2008-R-417
107. PSIC-2008-D-427
108. PSIC-2008-D-438
109. PSIC-2008-R-441
110. PSIC-2008-D-442
111. PSIC-2008-D-443
112. PSIC-2008-D-452
113. PSIC-2008-R-460
114. PSIC-2008-D-462
115. PSIC-2008-D-464
116. PSIC-2008-S33-465
117. PSIC-2008-R-470
118. PSIC-2008-R-476
119. PSIC-2008-D-477
120. PSIC-2008-D-478
121. PSIC-2008-D-479
122. PSIC-2008-D-480
123. PSIC-2008-R-483
124. PSIC-2008-A-485
125. PSIC-2008-D-487
126. PSIC-2008-R-490
127. PSIC-2008-R-500
128. PSIC-2008-D-502
129. PSIC-2008-R-503
130. PSIC-2008-R-509
131. PSIC-2008-D-510
132. PSIC-2008-S33-511
133. PSIC-2008-D-513
134. PSIC-2008-D-514
135. PSIC-2008-D-516
136. PSIC-2008-D-518
137. PSIC-2008-R-521
138. PSIC-2008-D-523
139. PSIC-2008-R-524
140. PSIC-2008-D-525
141. PSIC-2008-D-526
142. PSIC-2008-R-527
143. PSIC-2008-D-528
144. PSIC-2009-D-542
145. PSIC-2009-R-544
146. PSIC-2009-S33-546
147. PSIC-2009-S33-549
148. PSIC-2009-D-560
149. PSIC-2009-D-561
150. PSIC-2009-D-562
151. PSIC-2009-S33-563
152. PSIC-2009-D-564
153. PSIC-2009-S33-595
154. PSIC-2009-S33-600
155. PSIC-2009-D-601
156. PSIC-2009-S33-602
-
8/7/2019 Deloitte Final English
22/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 4
157. PSIC-2009-D-614
158. PSIC-2009-R-620
159. PSIC-2009-S33-635
160. PSIC-2009-R-636
161. PSIC-2009-D-638
162. PSIC-2009-S33-640
163. PSIC-2009-R-641
164. PSIC-2009-S33-645
165. PSIC-2009-S33-653
166. PSIC-2009-R-654
167. PSIC-2009-D-661
168. PSIC-2009-D-664
169. PSIC-2009-S33-669
170. PSIC-2009-D-685
171. PSIC-2009-S33-686
172. PSIC-2009-D-690
173. PSIC-2009-D-695
174. PSIC-2009-R-701
175. PSIC-2009-S33-706
176. PSIC-2009-D-710
177. PSIC-2009-R-724
178. PSIC-2009-R-725
179. PSIC-2009-D-726
180. PSIC-2009-D-728
181. PSIC-2009-D-729
182. PSIC-2009-R-733
183. PSIC-2009-D-741
184. PSIC-2009-D-745
185. PSIC-2009-R-749
186. PSIC-2009-S33-750
187. PSIC-2009-D-752
188. PSIC-2009-D-754
189. PSIC-2009-S33-756
190. PSIC-2009-R-767
191. PSIC-2009-D-770
192. PSIC-2009-S33-772
193. PSIC-2009-R-782
194. PSIC-2009-R-783
195. PSIC-2009-S33-786
196. PSIC-2009-D-787
197. PSIC-2009-R-792
198. PSIC-2009-D-794
199. PSIC-2009-S33-798
200. PSIC-2009-D-799
201. PSIC-2009-S33-801
202. PSIC-2009-S33-802
203. PSIC-2010-R-829
204. PSIC-2010-D-830
205. PSIC-2010-D-833
206. PSIC-2010-R-844
207. PSIC-2010-R-852
208. PSIC-2010-D-856
209. PSIC-2010-S33-864
210. PSIC-2010-D-867
211. PSIC-2010-D-874
212. PSIC-2010-R-887
213. PSIC-2010-R-895
214. PSIC-2010-R-905
-
8/7/2019 Deloitte Final English
23/24
Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 5
215. PSIC-2010-D-909
216. PSIC-2010-S33-914
217. PSIC-2010-D926
218. PSIC-2010-R-953
219. PSIC-2010-D-961
220. PSIC-2010-D-993
221. PSIC-2010-R-1005
-
8/7/2019 Deloitte Final English
24/24
www.deloitte.ca
Deloitte, one of Canada's leading professional services firms, provides audit, tax, consulting, and financial advisory servicesthrough more than 7,600 people in 57 offices. Deloitte operates in Qubec as Samson Blair/Deloitte & Touche s.e.n.c.r.l.Deloitte & Touche LLP, an Ontario Limited Liability Partnership, is the Canadian member firm of Deloitte Touche Tohmatsu Limited.
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network ofmember firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed