Information & Ethics Committee on Nov. 19th, 2025

[Gurbux Saini, Liberal, Fleetwood—Port Kells, BC]

Mr. Sabia, can you walk the committee through how a compliance screen fits into the broader integrity framework of the federal public service and the Conflict of Interest Act?

[Michael Sabia]

For the process, basically, as you know, there are two big elements to this.

The first is the creation of a blind trust, such that any assets are in a trust run by others, where decisions are made by others, and such that the public office holder, me included, has no ability to see inside that trust or to make any decisions with respect to it. That's the first step, and that's obviously pretty important, because if you don't have knowledge, and if you're not making decisions, that helps deal with the circumstances of the real or potential conflict of interest. That's number one.

Number two is that, in this case, there's another layer, which is a screen on top of that, to further respond to points that have been raised with respect to the confidence of Canadians and the transparency and accountability. Given the obvious decision-making role of the Prime Minister, layering on a screen on top of that protects against another potential risk, which is that an individual may not know exactly what is in that trust and not make decisions with respect to it, but they still might have some knowledge of particular types of assets.

The screen protects against that, and the screen says that other third parties—Mr. Blanchard, the Ethics Commissioner and I—have a role in ensuring, for issues that could arise, that the Prime Minister is protected against those circumstances and that those decisions are taken by other ministers. Those are the two layers of protection here: the blind trust and the screen. The two working together, I think, create a pretty solid basis for ensuring that the Prime Minister and the Office of the Prime Minister are seen to be of high integrity.

[Gurbux Saini, Liberal, Fleetwood—Port Kells, BC]

Thank you.

Can I ask you to speak to the safeguards that are in place to ensure that the conflict of interest compliance mechanisms are followed consistently across the government?

[Michael Sabia]

You've seen and we've distributed an assessment tool that is distributed across the government. In addition to the distribution and development of an assessment tool, and again, in co-operation with the commissioner, there is an extensive process of training so that individuals across the public service system have the same tool and the same training with respect to the operation of that assessment tool. That is an important element of how we build sensitivity across the public service system, not just in the Privy Council Office and not just in the Office of the Prime Minister, but also across the public service system and indeed across the system of political offices in departments across the system.

Our effort here is, in effect, to have everyone on the same page, to think the same way, to look for the same things and to raise the same flags. Those eventually percolate up into the Privy Council Office or up into the Office of the Prime Minister, where eventually the two administrators—the Prime Minister's chief of staff and I—take decisions as to whether or not the screen should be imposed.

I do want to reiterate something, though, and this is important. From the moment a flag is raised, a screen is imposed. It could be that when that issue comes to me or to Mr. Blanchard, or perhaps to the deputy secretary of governance of the Privy Council Office, we would say, “Wait a minute. It actually doesn't make sense. Yes, it's good to do that in an abundance of caution, but in fact, there's no need for a screen.” That has not happened, but it is conceivable, so that—

[The Chair, Conservative, John Brassard]

Thank you.

Forty-two seconds over and nobody is yelling in my ear that we're over time. I'm shocked.

We're going to reset the clock to the top of the hour.

Mr. Majumdar, you have six minutes. Go ahead, please.

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

Thank you, Chair.

Mr. Sabia, you mentioned earlier that you divested your assets, your Brookfield assets, because it's simpler. You wanted to avoid the appearance...and you made the decision 15 to 30 minutes after you saw Brookfield appear on the conflict screen, on the list itself. What does it say that the Prime Minister did not apply the same judgment that you did?

[Michael Sabia]

Here we go again. I think there are two different circumstances here. My job is to operate the screen and to make judgments with respect to when the screen ought to be applied. When the screen is applied, the Prime Minister is not included in the decision-making. The screen applies every time there is an issue that could be put to the Prime Minister that could come to the benefit of the companies listed on the list of 103 companies—

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

Right. Your screening—

[Michael Sabia]

—so because of that—

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

If I might, it's my time.

You're essentially saying that you are removing yourself from being conflicted as an administrator of the screen because the Prime Minister is conflicted.

[Michael Sabia]

No. I don't think I'm saying that. What I think I'm saying is that to protect the Prime Minister and the institution of the Office of the Prime Minister, my role is to make final decisions on whether or not a screen applies. For me not to have divested of that I think would have raised questions in my own mind about whether I could actually function in that role.

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

Let me take a different approach here. One of the items on the screen is the BGTF, the Brookfield Global Transition Fund. They hold specific portfolio assets. At no point is a screen invoked on those assets as a conflict in terms of what the Prime Minister is incented by. The Prime Minister is incented by the performance of the fund and its portfolio. Do departments across the government that work in this process have access to the portfolio components of BGTF?

[Michael Sabia]

Again, I would come back to my answer to Mr. Cooper on that. This is not about trying to track the various bits and pieces of what may or may not be in a fund. This is about understanding that the fund operates in a certain domain. By operating in that domain, that causes us to raise flags when we need to.

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

In the broad areas of what that fund operates in, the Prime Minister is engaged in very serious discussions that affect the future of the country. He is incented by knowing what's in that fund and what his performance pay would be based on that fund. How is it possible that he's engaging those industries without the screen being invoked?

[Michael Sabia]

But the screen would be invoked.

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

Based on the component assets of the BGTF?

[Michael Sabia]

Based on the sectors of operation. If we needed to, we would dig deeper. We would go, as I said, to the Ethics Commissioner, and we would get the information that was required if we needed it. Bear one thing in mind: We always err on the side of using the screen more broadly rather than narrowly. We always err on the side of an abundance of caution—always.

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

However, there has not been an abundance of caution, because the portfolio components of BGTF, which are specifically articulated as part of the screen, are not being screened by the departments.

[Michael Sabia]

The sectors in which that fund would operate are cause for a screen to be imposed. If there's any doubt or question about it—I'm repeating myself, and I apologize—we have access to the Ethics Commissioner and we use it.

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

Has the department or have you asked the Ethics Commissioner to understand what the components are of the BGTF?

[Michael Sabia]

We have not needed to up to now, because any time there was a perception of it, we put up a screen. That's been borne out by the Ethics Commissioner. It's been validated by the Ethics Commissioner.

[Shuv Majumdar, Conservative, Calgary Heritage, AB]

It comes back to the question I had originally. There are so many areas in which the Prime Minister is conflicted, based on his holdings. You made decisions to uphold the integrity of the office, but the Prime Minister has not made the same decisions to uphold the integrity of his office. How do you justify that scenario?

I ask this because across the institutional investment world, there are very strict screens, whether it's the CDPQ, Brookfield or the Bank of Canada, on how investments are intended to be structured, and if any individual investment team member is associated with it. The private sector, where you came from, has higher standards than what I see displayed in the tool and in the screen of the Government of Canada. How do you justify that?

[Michael Sabia]

Well, here's my answer to that. I ran what is now a $500-billion investment fund—

[The Chair, Conservative, John Brassard]

You're going to have to be quick, Mr. Sabia.

[Michael Sabia]

I ran a $500-billion investment fund for 11 years. It was $375 billion when I left.

We had lots of screens and ways of protecting against conflict of interest. We were able to do that successfully without any incident over the period of time that I was there, over that period of 11 years.

I would say that the operation of the screen here in the Government of Canada for the Prime Minister is every bit as rigorous as any screen I have seen in the private sector, pretty much ever.