I don't have any particular hesitations about a code of conduct for public servants. If you want to put it in legislation, that's fine.
A code of conduct is mostly what you carry around in your head. You don't pull out a little book every once in a while to see what you ought to do, but if it is useful as a general way of establishing an operating environment, I don't worry about it. I don't think it should get you into court very often, but perhaps I'm overlooking something.
On the question of the functioning of an accounting officer and responsibility to Parliament, I'm going to see if I can combine my response to Mr. Tonks and Mr. Owen.
When you go to a parliamentary committee, you really have to be ready to provide information about anything the committee wants, within obvious limitations of confidentiality. You have to be prepared to answer questions about whatever the committee raises; again, certain questions are off limits for an official, but I think you should be able to have very wide-ranging discussions with parliamentarians, because that's how you get them to understand better what you're trying to do. If that gets into the operations of the department--how well your policies are working, whether your programs are well designed--that's all part of it. You should be able to discuss that, as well as the nuts and bolts of the last financial report the Auditor General brought in.
On the question of audit, the legislation says you have to have an internal audit committee. I think all departments have internal audit committees. I know that every department in which I served as a deputy minister had an internal audit committee. I chaired it. The Auditor General was always invited to have a representative at the table. The Comptroller General was always invited to have a representative at the table. I always assumed that anything in our audits was going to become public, as it should. I have no problem with any of that.
The one rider is that you still I think need to preserve the principle that elected people are in charge. It doesn't mean they're to blame for everything that happens, but you work for the minister. The minister is the boss; the minister is elected and has prerogatives that you don't have.