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Confronting Caligula: Toward an Effective Ethical Infrastructure for Local Governments in Jacob L. Dicker

Where authority resides, so resides accountability, and if one has authority to strike a decision, then one has an obligation to provide an account.

Jocelyne Bourgon, Clerk of the Privy Council (ret.) (Savoie, 2012, p. 256)

Yes. I have smoked crack cocaine...Probably in one of my drunken stupors.

Rob Ford, Mayor of Toronto (Dale, 2013)

Introduction Sound governance is reliant on a shared sense of right and wrong; on a common acceptance of moral principles that ensure ethical behaviour and maintenance of the public interest therein (Lewis, 2008, pp. 44-45). Whereas individual adherence to these principles is not absolute, ethics must be upheld through codified norms so that errant behaviour by lone actors does not paralyze entire governments and undermine public trust in governing bodies. In practice, these codified norms may take form as codes of conduct, through the legal system or through independent bodies with a mandate to ensure ethical behaviour. Together, these contribute to ethical infrastructures whichwhen they operate effectivelycan help maintain good conduct within governments and thus enhance accountability to citizens.

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However, recent events have made it apparent that the ethical infrastructure in place for local politicians is inadequate in different municipalities across the country. In Quebec, for example, the Charbonneau Commission has unearthed numerous instances of corruption, leading to several high profile eigai, icldig ha f Meal Ma Alebam i Je 2013. Elehee, T (i)fam Ma Fd ha brought unsavoury attention to a city that has hitherto been known worldwide for the propriety of its governance and the politeness of its citizenry (Mayer, 2013). Through his actions, Ne Yk b he Si ha bee iled b eelai f Ford's drug- and alcohol-fuelled activities; exemplified most profoundly through his documented use of crack cocaine (Popik, 2006; Dale, 2013). Unfortunately, Ford's actions are not without parallel in Ontario. Indeed, in the last few years, the mayors of London and have also engaged in activities that are far from ethically sound. Ottawa's Larry O'Brien resigned in disgrace in 2009, and Mayor of London resigned in June 2014, nearly two years after he was alleged to have misused public funds for his son's wedding (Rollings, 2012; Maloney, 2014). Were these individuals at the helm of federal or provincial parties, their disregard for the propriety of elected officenever mind the lawwould likely have been addressed quickly through mechanisms of party discipline. Yet, because there are no parties at the municipal level in Ontario, and due to he ce ce f Oai Municipal Act, 2001 (OMA), and the City of Toronto Act (CTA), wayward politicians can remain in place for lengthy durations. While the provincial government at Queen's Park ultimately has the means to remove a sitting ma, gie ha micial geme ae ceae f he ice, dig cld eablih a deiable ecede and undermine the autonomy of municipal councils (Tindal and Tindal, 2009, pp. 178-179). A lack of removal mechanisms within the OMA (2001), which outlines the governance framework for Ontario communities outside of Toronto, provides a partial explanation for this paralysis. Indeed, a number of reforms to this legislation have been proposed recently, including calls for the establishment of a recall procedure which would allow citizens to

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remove elected officials between elections (Hildebrandt, 2013). In response, and due partly to scandals at the provincial level, the provincial government has recently introduced legislation that would enhance the powers of the Ontario Ombudsman to include oversight over municipalities, universities, schools, and hospitals (Public Sector and MPP Accountability and Transparency Act, 2014). While such proposals in the Public Sector and MPP Accountability and Transparency Act have merit, it is difficult to see how such an extension of direct provincial authority does not in itself undermine local government autonomy; a longstanding principle that ensures local councils have purpose and meaning (Reevely, 2014). Thus, in order to ensure that local politicians remain accountable without the risk of undue provincial influence in local affairs, the OMA and CTA should be reformed so that codes of conduct are made mandatory, and the mandates of municipal integrity commissioners should be strengthened in order to provide an effective check against potential misconduct. In the following pages, possible changes to the OMA and CTA, which can allow for enhanced codes of conduct and empowered integrity commissioners, will be discussed. Thereafter, thoughts on how this can work in practice are presented.

The Ontario Municipal Act and the City of Toronto Act: Ontario's Present Municipal Governance Framework Explained Local government has come under scrutiny in recent years due to the influence that neoliberalism, new public management, and globalization is thought to have had on all levels of government (Burns et al., 1994, p. 8). Cochrane (1991) has argued that in a post-Fordist ce, [e]leced lcal governments may continue to play an active role as mediators between different interests, managing those otherwise excluded, but more clearly than ever do so in an overall context which ackledge he le f bie (pp. 281-282, 299). Yet, accdig Mille ad Haki (2010), the entanglement of public and private sectors leads to the breakdown of notions of ethical behaviour and the collapse of the ability to police such adad a ei (. 568; Wedel, 2009). I hi context, where interaction between business and government leaders is more prevalent, it is vital that local governments possess robust ethical

Carleton Perspectives on Public Policy 50 infrastructure in order to ensure that accountability to the electorate and other democratic principles are maintained. Despite the marked changes of recent decades, micial geme i Oai emai ceae f he ice, hich lack diic ecgii i he cuntry's Constitution (Tindal & Tindal, 2009, pp. 10-11). Instead, they derive their legitimacy from provincial statutes. In Ontario, this has been covered by the OMA since 2001. The act outlines the structure and jurisdictional authority for local governments outside of Toronto, while the latter is governed under the CTA; an act that came into place in 1997 when a number of municipalities (e.g. Scarborough, North York) were merged into an amalgamated City of Toronto (Tindal & Tindal, p. 103; Sancton, 2003, p. 13). In 2006, this statutory framework was updated through the Municipal Statute Law Amendment Act, which introduced a range of voluntary and mandatory measures for local governments in order to improve accountability and transparency within their operations. These changes were introduced following a number of scandals that spurred the provincial government into action at the time (Alcantara et al., 2012, p. 121). For example, between 1998 and 1999, inappropriate actions by lobbyist Jeff Lyons (who sought favour for his clients by bribing councillors and officials) came to light at Toronto City Council (Tindal & Tindal, 2009, pp. 305-306). In response to what has been known as the MFP scandal ever since, an inquiry headed by Justice Denise Bellamy recommended that municipalities implement or update existing policies on procurement, public notices, or the delegation of authorities amongst other local government activities. In addition, the inquiry proposed that municipalities be empowered to enact codes of conduct and appoint accountability officers, such as integrity commissioners. (Alcantara, p. 121; Bellamy, 2005). As mentioned, the amalgamated City of Toronto has operated under its own legislative act since 1997 when the CTA became law. As Tindal and Tindal (2009) write, a majority of citizens in each of the six affected communities were opposed to the sweeping changes, which were imposed by the province egadle. I he ed, he el defied ci had bdaie bh big ad mall, becae i maiaied a geig structure that was inadequate for a city of that size. Furthermore,

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the reforms did not actually encompass the entire Greater Toronto Area as was originally envisioned (pp. 101-102). In 2005, attempts to redress this inadequate governance framework converged with the fallout from the MFP scandal when the provincial government further enhanced the city's authorities through the Stronger City of Toronto for a Stronger Ontario Act (2006). This law gave the city more revenue-raising options, greater authority over environmental policies, and gave it the power to deal directly with other governments. While the CTA and its counterpart (the OMA) are broadly similar, the CTA is different in that it specifically requires rather than empowersthe city government to appoint accountability officers and maintain a code of conduct. Although this demonstrates that the CTA and OMA already contain a number of provisions that are meant to uphold ethical behaviour at the municipal level, the differences between the CTA and OMA suggest that the application of these accountability measures is inconsistent across the province. While the fundamentals of an ethical framework exist, recent scandals in Ottawa, London, and Toronto are such that the time has come for Ontario's municipalities to update their ethical infrastructure. Recently, the provincial government under Kathleen Wynne has promised to ead he Oai Ombdma jidici i de address these existing issues at the local level. Currently, the Ombdma Office i limied i i abili ieigae ie of municipal misconduct, as it can only oversee occurrences within some closed-meeting circumstances, and only if municipalities opt in to such oversight (Office of the Ombudsman of Ontario, 2014). As mentioned at the outset of this article, the ed chage ld ead he ffice jidici i several areas, including municipalities. The bill has not been free of detractors however. While current Ombdma Ad Mai ha aed ha: Ontario is poised to rectify the accident of history that left millions of citizens with nowhere to complain about the public bodies that ched hei lie m clel, micial liicia like Oaa Ma Jim Watson have questioned the impact that this would have on local politicians (Office of the Ombudsman of Ontario, 2014). In response to the bill, Watson stated that he did hik i make a ee a all hae ahe lae f

Carleton Perspectives on Public Policy 52 bureaucracy dealing ih micial accabili (Bea, 2014). Indeed, rather than strengthen accountability within local governments, the proposed reforms represent a further dilution of local autonomy, and have the potential to further constrain lcal ccil alead limited capacity to uphold policies and act in the interest of residents (Woodside, 1990, pp. 199-200). Wa cmme eice he cce highlighed a he outset of this article. Whereas municipalities often lack effective ethical infrastructure, the appropriate policy response should be implemented at that level of government, rather than through blake efm a Qee Pak.

Codes of Conduct: Inadequate at the Best of Times Municipal codes of conduct are described in section 223.2 (1) of the OMA (2001), hee i i aed ha []ih limiig eci 9, 10 ad 11, hich lie micial jidici, he eci ahie he miciali establish codes of conduct for members of the council of the municipality and of local boards f he miciali (. 232.2 [1]). Similal, he CTA (1997) ae ha []he Ci hall eablih codes of conduct for members of city council and members of lcal bad (. 157). Tha cde f cdc deie i legiimac from a number of acts, including the Municipal Conflict of Interest Act (MCIA), the Municipal Elections Act, 1996, the Municipal Freedom of Information and Protection of Privacy Act, the Criminal Code, and the CTA itself. Even though the CTA mandates that the City of Toronto maintain the Code of Conduct for Members of Council, it is limited in scope, as it is only equipped to deal with councillors' conflict of interest issues (e.g. gifts and benefits, business relations, interaction with lobbyists). The concept of accountabilitya fundamental aspect of modern governance in Canadais scarcely mentioned in the document and, when it is, it is feebly applied. For those on Toronto City Council, accountability is only mentioned in the following circumstance:

Members of Council are accountable to the public through the four-year election process. Between elections they may, for example, become disqualified and lose their seat if

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convicted of an offence under the Criminal Code of Canada or for failing to declare a conflict of personal interest under the Municipal Conflict of Interest Act (City of Toronto, 2011).

As the above section indicates, Toronto's politicians are accountable to the electorate. In practice, however, they are in fact accountable to no one because only convictions under the Criminal Code, conflicts of interest, and inadequate attendance constitute circumstances under which a municipal politician may be removed from office. Tindal and Tindal (2009) also argue that the lack of constitutional recgii hgh Caada hi means that local governments are ultimately accountable to the ice becae hei fci, fiace, geig structureeven their very existencedepend on provincial authorization (2009, p. 10). However, Premier Wynne's tepid response to Mayor Ford's recent behaviour suggests that she does not intend to exercise that leverage and hold municipal mayors and councillors to account (City of Toronto, 2013). Though Ford's drug- and alcohol-fuelled activities have clearly violated the propriety expected of public officials, he remains mayor because he has not been charged under the Criminal Code (even though he has admitted to behaviour that would constitute offences under it). He has not explicitly violated the council's Code of Conduct for Members of Council (even though that code includes a section, however brief, on discreditable conduct), nor has he been absent from an unacceptable number of council meetings (City of Toronto, 2011, s. XIV). Ford has also not been found in violation of conflict of interest rules with respect to his recent behavioural issues, though as mayor he has previously been found in violation of conflict of interest rules due to his relationship with a high school football team. His potential removal from office was avoided in January 2013 after he appealed an earlier ruling of the Ontario Superior Court that found he violated the MCIA (Dhillon, 2013). Ford's staying power as mayor thus demonstrates the latitude with which municipal politicians can manoeuvre around the province's ethical infrastructure for local government. Elsewhere in the province, narrow readings of what is expected of council members have also been problematic. In Mississauga for instance, Mayor Hazel

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McCallion was accused of violating the MCIA for her actions in 2007 in relation to the awarding of contracts to her son's firm. While Justice Sproat criticized McCallion for not acting sensibly, his ruling did not require her to lose her seat (Grewal, 2013). While municipal governments in the province outside Toronto have the ability to establish codes of conduct, not all of them have. The optional nature of codes of conduct and accountability officers for Ontario municipalities outside Toronto has led to the inconsistent application of those empowerments. Municipalities that have so far implemented codes of conduct include Hamilton, Barrie, Kitchener, Brampton, Kawartha Lakes, , and London. Notably, Ottawathe second largest city in the provinceoperated without a code of conduct until April 2013 when Integrity Commissioner Robert Marleau introduced one (Boutilier, 2013). As it stands, municipal governments in Ontario lack effective codes of conduct either because they are limited in scope (as is the case in Toronto or Mississauga, for example), narrowly interpreted, or, as in many situations, they do not exist at all, therefore exemplifying significant shortfalls with respect to an ethical infrastructure for local government across the province

Ontario's Weak and Scarce Municipal Integrity Commissioners Thus far, it has been shown how the inconsistent application of codes of conduct by municipal councils across Ontario is a serious obstacle that must be overcome in order for an effective ethical framework to be realized. Yet, other reforms are also needed to bolster accountability mechanisms at the local level. Even if every municipality across Ontario had codes of conduct, they would hardly be enforceable without effective integrity commissioners. Currently, the OMA (2001) and CTA (1997) describe iegi cmmiie a beig eible f ch die a ma be aiged him he b he miciali. Commissioners are expected to maintain a lobbyist registry, and they have the authority to access all records, if deemed necessary to their investigations, which may be requested by members of council, local boards, or the general public. Although the existence of integrity commissioners is meant to enhance

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accountability within local government, they do not necessarily guarantee transparency because, as indicated in section 235.1, []he Cmmiie ad ee e acig de he instructions of the Commissioner shall preserve secrecy with respect to all matters that come to his or her knowledge in the ce f hi he die de hi Pa, ece f ifmai ha ma be dicled i a cimial ceedig a eied b la. Seci 161.3 f he CTA ad 223.5(3) f he OMA al indicate that this provision is to prevail over the Municipal Freedom of Information and Protection of Privacy Act. While integrity commissioners are the manifestation of a codified accountability mechanism for municipal councils, and are thus a positive presence, their ability to censure members who have violated codes of conduct is limited. As outlined in the OMA (2001), integrity commissioners are only able to issue reprimands if a member of council or local board has violated the code of conduct, and they have the authority suspend a member's pay for up to ninety days (2001, s. 223.4 [5]). Some municipalities enable additional measures while others do not. In Toronto for instance, the integrity commissioner may also suggest that Council carry out these options:

1. Removal from membership of a Committee or local board... 2. Removal as Chair of a Committee or local board... 3. Repayment or reimbursement of moneys received. 4. Return of property or reimbursement of its value. 5. A request for an apology to Council, the complainant, or both (City of Toronto, 2011, s. XVIII).

What emerges from this overview of municipal codes of conduct and the mandates for local integrity commissioners is a porous ethical framework that possesses large loopholes through which members of council can manoeuvre with relative ease. Rob Ford and Joe Fontana's longevity in office, despite their actions, are cases in point. While some measures toward an ethical framework exist in Ontario, the fact that two of the most prominent local government scandals of recent years have occurred in cities that have fully enacted their accountability mechanisms under provincial legislation (Toronto and London) demonstrates that these provisions are inadequate. This

Carleton Perspectives on Public Policy 56 suggests that the spate of scandals in Ontario's municipalities is due partly to structural factors. As Beeri and Navot argue (2013), there is a:

ibili ha chage i lcal geme acice e he a fe eahae improved public perceptions of corruption in local government. This means not only that corruption is perceived as structural, but also that the structural solution democratization may pave the way for even greater corruption (2013, p. 735).

It should be noted, however, their argument that structural reforms may pave the way for further corruption overlooks the positive role that empowered accountability officers can play. Reforms that can redress this situation have been proposed by others, including Justice Douglass Cunningham, who made eight recommendations in order to strengthen the ethical infrastructure for local governments across the province at the end of his 2011 inquiry into the conduct of Mayor Hazel McCallion of Mississauga. He recommended that the provincial government amend the Municipal Conflict of Interest Act by:

1. Extending its jurisdiction beyond the legislative functions of local councils; 2. Adding a preamble covering broad principles to the beginning of the Municipal Conflict of Interest Act; 3. Adding clarity to the scope of the act; 4. Defining the meaning of conflict more broadly beyond ecia iee; 5. Adding sanctions which are less severe than dismissal; 6. Giving individuals and electors greater ability to submit applications under the act; 7. Recognizing the powers of integrity commissioners (as is already the case in other acts); and 8. Making it clear that members of council are encouraged to make submissions related to integrity commissioners' reports (Poisson, 2011).

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While Justice Cunningham's recommendations were several, they did not call for substantial reforms to the role of integrity commissioners. This is likely the case because those positions are outlined under the OMA, which was not directly relevant to the McCallion case, which fell under the MCIA. As is being argued here though, enhancing the mandate for integrity commissioners is vital if municipal governments in Ontario are to possess adequate ethical frameworks. The following section describes how this enhanced mandate could work in practice. Empowered Integrity Commissioners in Practice Whereas the CTA already requires that Toronto City Council have an integrity commissioner, the language from that act can be implemented into a revised OMA in which integrity commissioners would be mandatory in each local government. To date, fewer than 40 of Ontario's 444 municipalities have established integrity commissioners since they were authorized to do so through the OMA in 2001 (City of Brampton, 2012; Office of the Conflict of Interest Commissioner, 2012). This would mean revising section 223.3 of the OMA, which currently reads as follows:

Without limiting sections 9, 10 and 11, those sections authorize the municipality to appoint an Integrity Commissioner who reports to council and who is responsible for performing in an independent manner the functions assigned by the municipality with respect to, (a) the application of the code of conduct for members of council and the code of conduct for members of local boards or of either of them; (b) the application of any procedures, rules and policies of the municipality and local boards governing the ethical behaviour of members of council and of local boards or of either of them; or (c) both of clauses (a) and (b). 2006, c. 32, Sched. A, s. 98 (s. 233.3). The revised section could read as such:

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Without limiting sections 9, 10 and 11, the municipality shall appoint an Integrity Commissioner who reports to council and who is responsible for performing in an independent manner the functions assigned by the municipality...

While Toronto and other municipalities in the province already have integrity commissioners in place, the various instances of unethical behaviour discussed previously require a stronger mandate for these officials once their existence is made mandatory. This strengthened mandate could be achieved through the following reforms: 1. Provide integrity commissioners with a wider range of sanctions. Currently, integrity commissioners can only impose a reprimand, or a suspension of pay for ninety days on members of council found in violation of the code of conduct. Providing them with more sanctioning options would fulfill one of the recommendations made by Justice Cunningham when ruling on the McCallion case in Mississauga. 2. Make the work of integrity commissioners transparent in all matters. To date, the OMA and CTA require integrity cmmiie eee ecec ih eec all mae that come to his or her knowledge in the course of his or her die, ece he ha ifmai i be dicled i a criminal proceeding (OMA, 2001, s. 223.5 ([1]). However, it is hardly in the public interest to have the operations of municipal integrity commissioners cloaked in a veil of secrecy that overrides public access rights granted by the Municipal Freedom of Information and Protection of Privacy Act. 3. Make periodic reports by integrity commissioners mandatory. As written in section 223.6 (1) of the OMA and section 162 (1) of the CTA, periodic reports by integrity commissioners are optional depending on the practice established by the municipality. Changing both acts so that periodic reports are a bona fide requirement of the position can serve the public interest through increased transparency.

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Some municipalities in Ontario have already moved independently toward enhancing the role of integrity commissioners. In Windsor, for instance, the integrity commissioner's mandate is summarized into four areas: advisory, complaint investigation, complaint adjudication, and education. With respect to education, he or she is required to:

...provide, as required, outreach programs to members of Council and staff on legislation, protocols and office procedures emphasizing the importance of ethics for public confidence in municipal government; and will disseminate information regarding the Office of Integrity Commissioner to the public (City of Windsor, 2013).

The mandate for Windsor's integrity commissioner offers an example that other local governments across the province can follow. Similar language is provided by Toronto's Office of the Integrity Commissioner, but recent events involving Mayor Ford demonstrate the necessity in providing additional statutory authority to integrity commissioners if an effective ethical framework is to be realized in Ontario's municipal governments. In terms of size, Ontario's municipalities vary widely, from some incorporated villages with only a few hundred inhabitants, to the City of Toronto, which has more people than five Canadian provinces combined (Fernando, 2007, p. 440). While large cities are quite capable of adopting these proposed reforms (if they have not already done so), small municipalities may have more difficulty due to insufficient human resources within their boundaries. The province could give consideration to this by allowing smaller communities to pool their resources and establish integrity commissioners at upper-tier levels of municipal government (e.g. counties, districts). While the province has proposed legislation to enhance the role of the Ontario Ombudsman by allowing that office to oversee municipalities, universities, schools, and hospitals, a number of shortfalls with that proposal emerge. The province certainly has the authority to make sweeping changes at the lcal leel, gie micialiie eablihme a ceae of

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he ice, b e m ei he imac lcal autonomy under an empowered Ombudsman. Also, given the large number of municipal governments, universities, schools, and hospitals across the province, it is unclear whether the Ontario Ombudsma ffice cld maiai he caaci properly investigate all instances of misconduct. Instead, legislating changes to municipal integrity officers can ensure that accountability is upheld without the risk of local autonomy being undermined.

Conclusion I Decembe 2013, i ligh f Rb Fd idicei since becoming Mayor of Toronto, Andrew Coyne (2013) wrote ha heea hee a a ime he blic fficial aced ihi me f limi, i aeaed ha accabili mechaim within our system of government were now inadequate. Indeed, me fficial ee cleal illig eecie a e cem f cial m, h demiig he haed mal icile, and shared sense of right and wrong that underpins sound governance. A he media ecacle dig Fd ebe behaviour reached its height, apt comparisons between the mayor and unsavoury tyrants emerged. Unmovable from office, unaccountable to anyone, and unpredictable at the best of times, it was an American celebrity chef who eventually equated Ford to a modern day Caligula (Bourdain, 2013). As a result, calls for the province step in were widespread. Some commentators called f Qee Pak ac diecl, hile i a al suggested that the introduction of a municipal recall mechanism would do a great deal to address this and other examples of local government misconduct. Yet, what must also be addressed in light of these debacles is the ineffective ethical infrastructure in place for municipal politicians in Ontario. While there have been many scandals in recent years, few resignations or dismissals from local councils have occurred. As a result, Fontana, Ford, and others were able (and in some cases continue) to prevail in office for months and even years after allegations of inappropriate behaviour come to light. These unacceptable circumstances emerge because of a combination of weak codes of conduct, an insufficient spectrum of sanctions that can be

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applied to redress misconduct, and the fact that integrity commissioners are not mandatory for municipal governments across the province. Thus, it remains that the empowerment of municipal integrity commissioners can overcome the alarming disregard for the propriety of office that too many municipal politicians have recently demonstrated across the province. There is a precedent for such reforms given that the provincial government first allowed for the introduction of integrity commissioners and codes of conduct following scandals in the early 2000s. The recent introduction of reforms for the Ontario Ombudsman also demae he ice illige adde hfall i municipal accountability, but it remains that those proposed changes act as an extension of provincial authority. While local goverme ae ideed ceae f he ice, he efm presented here show how accountability mechanisms can be enhanced without undermining local autonomy. The options presented in this analysis demonstrate how those existing provisions in the OMA and CTA can be expanded upon in order to strengthen the mandates of municipal integrity commissioners and guarantee their presence in jurisdictions across the province. Though it would be inappropriate to suggest that this enhanced role for integrity commissioners could serve as a guarantor against future scandals, the implementation of such measures can, at the very least, help instill a culture of ethics underpinned by the knowledge that when rules are flouted, consequences will follow.

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Bea, R.J. (2014, Nembe 7). Sme micialiie a mbdma Ad Mai kee . Toono Sa. Reieed fm: h://.hea.cm/e/eeak/2014/07/07/ me_micialiie_a_mbdma_ad_mai__k ee_.hml. Burns, D., Hambleton, R. and Hogget, P. (1994). The Politics of Descentralization: Revitalizing Local Democracy. London, UK: Palgrave Macmillan. Cochrane, A. (1991). The Changing State of Local Government Restructuring. Public Administration, 69(3), 281 302. Coyne, A. (2013, November 18). Rob Ford doesn't need to hear 'get help'. He needs to hear 'get out'. . Retrieved from: http://fullcomment.nationalpost.com/2013/11/18/andrew- coyne-rob-ford-doesnt-need-to-hear-get-help-he-needs- to-hear-get-out/. Dale, D. (2013, November 5). Rob Ford: 'Yes, I have smoked crack cocaine'. . Retrieved from: http://www.thestar.com/news/crime/2013/11/05/rob_ford _yes_i_have_smoked_crack_ cocaine.html. Dhillon, S. (2013, June 20). Rob Ford ready to 'move on' from conflict-of-interest case after appeal rejected. The Globe and Mail. Retrieved from: http://www.theglobeandmail.com/news/toronto/supreme- court-to-decide-today-if-it-will-hear-appeal-against-rob- ford/article12700892/. Fernando, S. (2007). Ethics and good urban governance in Toronto: the Bellamy report and integrity in public service. Canadian Public Administration, 50(3), 437 448. Grewal, S. (2013, June 14). Mississauga Mayor Hazel McCallion not guilty of conflict of interest. Toronto Star. Retrieved from: http://www.thestar.com/news/gta/2013/06/14/mississaug a_mayor_hazel_mccallion_not_guilty_of_conflict_of_inte rest.html.

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(2012). Office of the Integrity Commissioner. Brampton, ON: City of Brampton. Retrieved from: http://www.brampton.ca/EN/City- Hall/Pages/IntegrityCommissioner.aspx. Office of the Conflict of Interest Commissioner. (2012). Municipal Integrity Commissioners. Toronto, ON: Government of Ontario. Retrieved from: http://www.coicommissioner.gov.on.ca/scripts/en/munici pal.asp. Office f he Ombdma f Oai. (2014, Mach 6). Oai Ombdma eigh be eaded MUSH ec: Mai elcme hiic me ide ci f micialiie, chl bad, hial ad me. Reieed fm: h://.mbdma..ca/Nem/Pe- Releae/2014/Oai-Ombdma-eigh--be- eaded--MUSH.a. Poisson, J. (2011, October 3). Overhaul municipal conflict rules, inquiry head urges. Toronto Star. Retrieved from: http://www.thestar.com/news/gta/2011/10/03/overhaul_ municipal_conflict_rules_inquiry_ head_urges.html. Popik, B. (2006, July 30). New York run by the Swiss (summary). The Big Apple. Retrieved from: http://www.barrypopik.com/index.php/new_york_city/entr y/new_york_run_by_the_swiss_summary/. (2012). Resignation of Mayor Joe Fontana from London Police Services Board. London, ON: London Police Service. Retrieved from: http://www.police.london.ca/d.aspx?s=%2FNewsroom% 2F2012475.htm. Reeel, D. (2014, Mach 24). Pice la hae mbdma ecd-ge ci ccil. Oaa Ciien. Reieed fm: h://.iick.ca/aa/eeel- ice-la--hae-mbdma-ecd-ge-ci- ccil.

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Rollings, R. (2012, November 21). Mr. Joseph Fontana Charged. London, ON: Royal Canadian Mounted Police. Retrieved from: http://www.rcmp-grc.gc.ca/on/news- nouvelles/2012/12-11-21-london-eng.htm. Sancton, A. (2003). Why Municipal Amalgamations? Halifax, Montreal, Toronto. Paper presented at the Conference on Municipal-Provincial-Federal Relations in Canada. Kingston, ON: Queen's University Institute of Intergovernmental Relations, May 9-10. Savoie, D. (2012). Court Government and the Collapse of Accountability in Canada and the United Kingdom. Toronto, ON: University of Toronto Press. Stronger City of Toronto for a Stronger Ontario Act, Statues of Ontario (2006, c. 11). Retrieved from e-Laws Ontario: http://www.e- laws.gov.on.ca/html/source/statutes/english/2006/elaws_ src_s06011_e.htm. Tindal, C.R. and Tindal, S. (2009). Local Government in Canada, Seventh Edition. Toronto, ON: Birchmount Education. (2013). Toronto City Council and Committees Meetings, Agendas, and Minutes. Toronto, ON: City of Toronto. Retrieved from: http://app.toronto.ca/tmmis/getAdminReport.do. Wedel, J. (2009). The Shadow Elite: How the World's New Power Brokers Undermine Democracy, Government, and the Free Market. New York, NY: Basic Books. Wdide, K. (1990). A aach dig lcal geme am: he Oai eeiece. Canadian Pblic Adminiaion, 33(2), 198-213.

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