IDRC's conflict of interest policy: does it apply to Barbara McDougall? to the rest of IDRC's staff?

Here is IDRC's conflict of interest policy. It makes for interesting reading:

Conflict of Interest

A conflict of interest exists in any situation where employees' ability to fulfill their official duties and responsibilities could be adversely affected by their private interests or personal considerations. This goes beyond a financial or economic interest to include any personal interest that arises from business dealings, social ties, or other personal considerations.

As employees of the Centre, we conduct ourselves and perform our duties in a manner that reflects the values, principles, standards, and best interests of IDRC, and in a transparent way that enhances public confidence and trust in the integrity of the Centre.

We act in a manner that will bear the closest public scrutiny and foster public confidence.

We strive to avoid situations that place us in an actual, potential, or apparent conflict of interest and report on all such conflicts, in accordance with the Centre's governing policies. We regularly review IDRC's conflicts of interest policies to ensure compliance and raise any concerns we may have directly with our fellow employees, supervisor, or if unadvisable or inappropriate, the next level of supervision.

And further:

When faced with a difficult business decision that is not addressed in this Code, a few questions may help us determine the appropriate course of action:

Is it ethical?

Is it legal?

Is the decision defensible in the eyes of the public?

What would a reasonable person think about our decision/action?

Does it have the potential to reflect negatively on DRC or us?

Would we be embarrassed if others knew we took this action?

Is there an alternative course that may not pose the same ethical conflict/dilemma

If still in doubt about a situation or whether it is consistent with IDRC's high ethical standards, we must seek help and guidance from our supervisor, or if inappropriate or otherwise unadvisable to do so, the next level of supervision, or such other office that may be designated from time to time.

We, members of management and staff alike, are all responsible for ensuring that we read, understand, and uphold the values, principles and standards outlined in the Code and in the supporting Centre policies. To be effective, the Code must be integral to everything we do.

Avenue of Resolution

Concerns about this Code and its application should first be discussed with management. When unable to raise the concern with a direct supervisor, we are to consult the next higher level of authority or, ultimately, such other office that may be designated from time to time.

In all cases, reporting requirements related to the disclosure of wrongdoings and the protections afforded to those employees who, acting in good faith and without being frivolous or vexatious, have made an allegation of wrongdoing, will be consistent with the requirements of the Public Servants Disclosure Protection Act.

Failure to Comply

The Code forms part of our conditions of employment at IDRC. We are expected to operate within and uphold the highest standard of conduct. We understand that any failure to do so will be viewed as falling short of IDRC's acceptable standards of conduct as defined in the Management Policy Manual, Section 4.28 - Discipline, and may therefore lead to disciplinary action.