HomeMy WebLinkAboutCLK 06-26
Report to
Council
Report Number: CLK 06-26
Date: June 22, 2026
From: Paul Bigioni
Director, Corporate Services & City Solicitor
Subject:
Appointment of an Integrity Commissioner and Lobbyist Registrar
2026-2030 Term of Council
File: A-1440
Recommendation:
1. That Report CLK 06-26 regarding the Appointment of an Integrity Commissioner and
Lobbyist Registrar for the 2026-2030 Term of Council be received;
2. That Boghosian + Allen LLP be appointed as the City of Pickering’s Integrity Commissioner
and Lobbyist Registrar for the 2026-2030 Term of Council commencing on November 15,
2026, with the option to renew for an additional Council Term;
3. That the draft agreement, included as Attachment 1 to this report be approved, subject to
any minor revisions acceptable to the City Clerk and the Director, Corporate Services &
City Solicitor, and that the Mayor and City Clerk be authorized to execute the agreement;
4. That the draft by-law included as Attachment 2 to this report to confirm the appointment of
Boghosian + Allen LLP as the provider of Integrity Commissioner and Lobbyist Registrar
services for the City of Pickering be enacted; and,
5. That the appropriate officials of the City of Pickering be authorized to take the actions
necessary to implement the recommendations in this report.
1.0 Executive Summary:
The purpose of this report is to appoint an Integrity Commissioner and Lobbyist Registrar for
the 2026-2030 Term of Council. The contract with Principles Integrity, the City’s current
Integrity Commissioner, expires on November 14, 2026. This report is seeking approval to
execute a contract for the next Term of Council to ensure that a new Integrity Commissioner is
in place for the start of the new Term which begins on November 15, 2026.
It is proposed that David Boghosian serve as Integrity Commissioner and Lobbyist Registrar
and have primary responsibility for carrying out all aspects of those roles including liaising with
the City, Members of Council and local boards and members of the public, providing advice to
Members of Council, directing investigations and inquiries and authoring and delivering reports
CLK 06-26 June 22, 2026
Page 2
to Council. Other members of Boghosian + Allen LLP will assist David Boghosian with the
Integrity Commissioner/Lobbyist Registrar Contract.
2.0 Relationship to the Pickering Strategic Plan:
The recommendations in this report respond to the Pickering Strategic Plan Priority of Foster
an Engaged & Informed Community.
3.0 Financial Implications:
In accordance with the draft Agreement (Attachment 1), the fees for Integrity Commissioner
and Lobbyist Registrar services fluctuate based on which individuals of Boghosian + Allen LLP
render their services. Services rendered by David G. Boghosian are $350.00/hour, while
services rendered by junior lawyers are $260.00/hour and $160.00/hour for law clerks or
students. These fees are not inclusive of HST.
Due to the integrity commissioner services being used on an as-needed basis, it is difficult to
determine the total annual costs. Dedicated funds in the amount of $135,000.00 have been
included in the 2026 Budget to cover costs associated with Code of Conduct complaints and
investigations and $8,000.00 has been included for education, training and consulting services
related to the Code of Conduct and Lobbyist Registry. A similar amount will be proposed for
the 2027 Budget to cover the fees for services rendered.
4.0 Discussion:
The purpose of this report is to appoint an Integrity Commissioner and Lobbyist Registrar for
the 2026-2030 Term of Council. The contract with Principles Integrity, the City’s current
Integrity Commissioner, expires on November 14, 2026. This report is seeking approval to
execute a contract for the next Term of Council to ensure that a new Commissioner is in place
for the start of the new Term which begins on November 15, 2026.
Pursuant to Subsection 223.3(1) of the Municipal Act, 2001, S.O. 2001, c. 25 (the “Act”), the
Integrity Commissioner reports to Council and is responsible for performing, in an independent
manner, the functions assigned by the municipality.
Integrity Commissioners carry out a range of functions for municipalities including:
• The application of the code of conduct for Members of Council and the Code of Conduct
for members of local boards.
• 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.
• The application of sections 5, 5.1, 5.2 and 5.3 of the Municipal Conflict of Interest Act to
Members of Council and of local boards.
• Requests from Members of Council and of local boards for advice respecting their
obligations under the Code of Conduct applicable to the Member.
• Requests from Members of Council and of local boards for advice respecting their
obligations under a procedure, rule, or policy of the municipality or of the local board, as
the case may be, governing the ethical behaviour of members.
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Page 3
• Requests from Members of Council and of local boards for advice respecting their
obligations under the Municipal Conflict of Interest Act.
• The provision of educational information to Members of Council, members of local
boards, the municipality and the public about the municipality’s Codes of Conduct for
Members of Council and members of local boards and about the Municipal Conflict of
Interest Act.
• Recommending the imposition of penalties in accordance with the Act if in the opinion of
the Integrity Commissioner a Member of Council has contravened the Code of Conduct.
For municipalities that have a lobbyist registry program, the Integrity Commissioner is often
also appointed as the Lobbyist Registrar to respond to complaints or issues pertaining to the
Municipal Lobbyist Registry. By-law 8003/23, being a by-law to establish and maintain a
Lobbyist Registry for the City of Pickering, states “The City of Pickering’s Integrity
Commissioner is herein appointed as the Lobbyist Registrar in accordance with section 223.11
of the Municipal Act, 2001.” The draft by-law included as Attachment 2 to this report proposes
to formally appoint Boghosian + Allen LLP as the City’s Lobbyist Registrar and includes the
duties associated with that role.
Over the last few Terms of Council, the Region of Durham and some area municipalities have
undertaken a collaborative RFP process for the selection of an Integrity Commissioner. This
process was initiated again in January 2026. The process to secure Integrity Commissioner
services for the next term of Council followed the Durham Region’s Consultant and
Professional Services Contracting Procedure. Invitations to enter into a consulting and
professional services contract with the Region and local municipalities were sent to nine
individuals/firms. Three proposals were received and evaluated. Respondents participated in
presentation and interview sessions which were evaluated by the Region, and the Municipal
Clerks or Deputy Clerks from Oshawa, Pickering, Uxbridge and Whitby. The top two
submissions received were Principles Integrity and Boghosian + Allen LLP and the scores of
those two proposals were tied.
On April 28, 2026, after the RFP evaluations had taken place, the City received a Notice of
Termination from Principles Integrity advising that they would no longer be providing integrity
commissioner services to any municipalities for the 2026-2030 Term of Council. Up until the
receipt of the Termination Notice, City staff were prepared to recommend the services of
Principles Integrity for the 2026-2030 Term of Council given that their services were
satisfactory to the City and their recommendations pertaining to Code of Conduct violations
were upheld by the Divisional Court in two hearings regarding three separate judicial review
applications. With the Notice that Principles Integrity will no longer be providing integrity
commissioner services, and with Boghosian + Allen LLP receiving the same score as
Principles Integrity in the RFP process, Boghosian + Allen LLP is now the successful
proponent being recommended by staff to provide Integrity Commissioner and Lobbyist
Registrar services for the 2026-2030 Term of Council. Durham Region Council approved the
appointment of Boghosian + Allen LLP as its Integrity Commissioner at its meeting held on
April 29, 2026. It is anticipated that the remaining participating municipalities will be taking
recommendations to appoint Boghosian + Allen LLP to their respective Councils.
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Page 4
Boghosian + Allen LLP (formerly Boghosian + Associates PC) is a leading Ontario law firm
servicing municipalities across Ontario in the areas of general municipal law, general civil
litigation, municipal defence litigation and accountability/transparency services. Founded by
David Boghosian in 2005, the firm has provided legal services to dozens of municipalities as
well as other public entities. The firm is currently comprised of 10 lawyers, supported by
articling and summer students, law clerks, legal assistants and administrative staff.
David Boghosian is currently the Integrity Commissioner (IC) for 13 municipalities (Fort
Frances, Hamilton, Caledon, Haldimand County, Kirkland Lake, Norfolk County, Bonfield,
Temagami, Stratford, Prince Edward County, Cornwall, East Ferris and Red Lake). He is the
Lobbyist Registrar for Hamilton and Niagara Region.
Outside of and/or predating his formal IC roles, his retainers for municipalities have included
numerous accountability services assignments. These include Municipal Conflict of Interest
Act, Municipal Elections Act and Code of Conduct investigations, serving as a compliance
audit adjudicator in Municipal Elections Act challenges to campaign finance expenditures, and
involvement in municipal auditor general investigations. David Boghosian also worked for the
Ontario Office of the Ombudsman while in law school and thereby gained first-hand knowledge
of the conciliatory approach employed in that office.
David Boghosian is the Lobbyist Registrar for the City of Hamilton and Niagara Region. David
and his accountability services team are experienced in providing comprehensive lobbyist
registry training, responding to requests for advice and investigating/determining alleged
breaches of and enforcing lobbyist registry by-laws. The investigations undertaken by the team
have included factually and legally complex investigations related to high profile housing policy
issues.
Due to the RFP process undertaken and the evaluation of the proponents, along with the
Notice of Termination provided by Principles Integrity, staff recommend the appointment of
Boghosian + Allen LLP as the City’s Integrity Commissioner and Lobbyist Registrar for the
2026-2030 Term of Council, with the option to renew for an additional Term should their
services be satisfactory to the City of Pickering.
Attachments:
1. Draft Agreement for Integrity Commissioner and Lobbyist Registrar Services between
the City of Pickering and Boghosian + Allen LLP
2. Draft By-law to Appoint Boghosian + Allen LLP as the City’s Integrity Commissioner and
Lobbyist Registrar
Prepared By: Susan Cassel, City Clerk
Approved/Endorsed By: Paul Bigioni, Director Corporate Services & City Solicitor
CLK 06-26 June 22, 2026
Page 5
SC:ks
Recommended for the consideration of Pickering City Council By:
Marisa Carpino, M.A.
Chief Administrative Officer
Attachment 1 to Report CLK 06-26
Attachment 2 to Report CLK 06-26
The Corporation of the City of Pickering
By-law No. XXXX/26
Being a by-law to confirm the Appointment of Boghosian +
Allen LLP as the Integrity Commissioner and Lobbyist Registrar
for the City of Pickering
Whereas Section 223.3 of the Municipal Act, 2001, S.O. 2001, c. 25 (the “Act”), authorizes a
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;
And Whereas Section 223.11 of the Act, authorizes the City of Pickering to
appoint a Lobbyist Registrar who is responsible for performing in an independent manner the
functions assigned by the City of Pickering with respect to a Lobbyist Registry;
And Whereas Sections 8, 9, and 10 of the Act, authorize the City of Pickering
to pass by-laws that are necessary or desirable for municipal purposes, and in particular
paragraph 2 of subsection 10(2) authorizes by-laws respecting the accountability and
transparency of the municipality and its operations;
And Whereas the current contract for Integrity Commissioner and Lobbyist Registrar services
for the City of Pickering will expire on November 14, 2026;
Now therefore the Council of The Corporation of the City of Pickering hereby enacts as follows:
1. That Boghosian + Allen LLP, is hereby appointed as the Integrity Commissioner and
Lobbyist Registrar for the City of Pickering; and,
2. That in accordance with the agreement between Boghosian + Allen LLP, as the City of
Pickering’s Integrity Commissioner and Lobbyist Registrar, and the City of Pickering, the
following roles and services shall be provided:
Role:
In accordance with Section 223.3(1) of the Municipal Act, the role of the Integrity
Commissioner is:
(a) The application of the Code of Conduct for Members of Council and for members of
local boards;
(b) The application of any procedures, rules and policies of the City and local boards
governing the ethical behaviour of Members of Council and local boards;
(c) The application of sections 5, 5.1, 5.2 and 5.3 of the Municipal Conflict of Interest
Act to Members of Council and local boards;
By-law No. "[Click here and type By-law #]" Page 2
(d) Respond to requests from Members of Council and of local boards for advice
respecting their obligations under the Code of Conduct applicable to the member;
(e) Respond to requests from Members of Council and of local boards for advice
respecting their obligations under a procedure, rule or policy of the City or of a local
board, governing the ethical behaviour of members;
(f) Respond to requests from Members of Council and of local boards for advice
respecting their obligations under the Municipal Conflict of Interest Act; and,
(g) Provide educational information to Members of Council, local boards, the City and
the public about the City’s Code of Conduct and the Municipal Conflict of Interest
Act.
Duties:
The Integrity Commissioner shall cause to perform, in an independent manner, the
functions of an Integrity Commissioner pursuant to Part V.1 of the Municipal Act, with
respect to the application of the Code of Conduct for Members of Council and of local
boards, of the City of Pickering, including any legislation, procedures, rules and policies of
the City governing the ethical behaviour of the Members. The mandate of the Integrity
Commissioner includes:
(a) Providing advice and education upon request by a Member or by Council or the local
board as a whole, regarding ethical obligations and responsibilities under their Code
of Conduct, and any other legislation, rules or policies governing their ethical
behaviour;
(b) Receiving, assessing and investigating where appropriate, complaints may by
Council, a Member of Council, a local board, a member of a local board, a member
of staff, or a member of the public respecting an alleged breach of the City’s Code of
Conduct through the provisions of the Code of Conduct and any Procedures for
complaints;
(c) Receiving, assessing and conducting an inquiry, where appropriate, with respect to
requests for inquiry made by an elector, or a person demonstrably acting in the
public interest concerning an alleged contravention of section 5, 5.1, 5.2 or 5.3 of the
Municipal Conflict of Interest Act;
(d) Giving advice on policy issues and the workings of the City’s Integrity
Commissioner’s office; and,
(e) All advice being provided in writing in accordance with the requirements of Section
223.3(2.2) of the Municipal Act;
The Integrity Commissioner shall cause to perform, in an independent manner, the
functions of a Lobbyist Registrar in accordance with section 223.11 of the Municipal Act,
and By-law 8003/23 which includes but is not limited to:
By-law No. "[Click here and type By-law #]" Page 3
(a) providing advice, opinions and interpretation pertaining to the administration,
application and enforcement of the Lobbyist Registry By-law;
(b) conducting inquiries in respect of a request made about compliance with the Lobbyist
Registry By-law, which may include requesting that a Public Office Holder gather
information concerning Lobbying of themselves and provide that information to
Lobbyist Registrar;
(c) enforcing the Lobbyist Registry By-law;
(d) suspending, revoking or refusing a Registration or Return;
(e) advising Council on Lobbying matters and recommending improvements to the
Lobbyist Registry By-law; and,
(f) providing an annual report to Council and any other reports as the Lobbyist Registrar
considers appropriate.
Reporting to Council:
(a) The Integrity Commissioner will report directly to Pickering City Council with a report
containing the results of investigations and one annual report summarizing the
year’s activities, observations, and any resulting general recommendations including
reporting on matters pertaining to the City’s Lobbyist Registry; and,
(b) The Integrity Commissioner may recommend that City Council impose penalties in
accordance with the Municipal Act if in the opinion of the Integrity Commissioner, a
Member has contravened the Code of Conduct.
Other General Provisions:
(a) Should the Integrity Commissioner conduct an investigation or provide any other
service, it shall do so in accordance with the terms and conditions of the Agreement
executed between it and the City of Pickering and shall adhere to all applicable laws,
applicable statutes, and established City Policies; and,
(b) All services provided by the Integrity Commissioner shall conform to all the statutory
requirements of Section 223.3 to 223.12 of the Municipal Act.
3. That By-law 7956/22 be repealed effective November 14, 2026.
4. That this By-law shall come into effect as of November 15, 2026.
By-law passed this 22nd day of June, 2026.
________________________________
Kevin Ashe, Mayor
By-law No. "[Click here and type By-law #]" Page 4
________________________________
Susan Cassel, City Clerk