Site Accessibility Information Access Key 1 to Skip to Top Navigation Access Key 2 to Skip to the Three One One link Access Key 3 to Skip to City of Winnipeg Main Menu Access Key 4 to Skip to Left Navigation Menu Access Key 5 to Skip to Content area Access Key 6 to Skip to Right Sidebar content area Access Key 7 to Skip to Footer Links
City of Winnipeg
|  Link to the City of Winnipeg French websiteFrançais  |

City Clerk's

Integrity Commissioner

Role of the Integrity Commissioner

The Integrity Commissioner is an independent position appointed by Council for a fixed two-year term, renewable up to five times.

The mandate for the Integrity Commissioner was set out in the Minutes from the Council Meeting of December 9, 2015 at Appendix C.

Pursuant to that mandate, the Integrity Commissioner's role is to:

  • Assist Members of Council in understanding their ethical obligations under The Municipal Council Conflict of Interest Act, the Code of Conduct and any other by-laws, policies of Acts governing the behaviour of Council, to identify areas of possible conflict and to provide Members with advice on preventing conflicts and breaches of ethical conduct from occurring;
  • Investigate complaints made about Members of Council which relate to alleged violations of the Code of Conduct;
  • Oversee the City of Winnipeg Voluntary Lobbyist Registry.

Open allClose all

Message from the Integrity Commissioner

The new position of Integrity Commissioner is a tremendous opportunity for the City. Establishing an ethics regime which includes an Integrity Commissioner enhances accountability, transparency and fairness – all necessary features for the functioning of good, effective government. Although many municipalities in Ontario have benefited from the guidance and oversight of an Integrity Commissioner, the City of Winnipeg is only the third municipality in western Canada to create such a position.

The Integrity Commissioner reports to Council in Annual Reports which will summarize the Commissioner’s activities. Reports will also be made on a periodic basis as necessary. Ultimately reports will be issued on the investigations of complaints once a Complaint Protocol has been established and approved by Council.

Advice and Education

The most important role of the Integrity Commissioner, which will have the most impact, is to ensure that Members of Council understand the ethical responsibilities they take on when they assume office. Those responsibilities require each Member of Council to perform his or her duties of office and arrange his or her private affairs in such a manner as to maintain public confidence and trust in the integrity, objectivity and impartiality of the Member.


The ability to complain about unethical conduct is an essential mechanism for enforcing accountability in government and ensuring that ethical rules are followed.

Council has shown it understands the importance of this by giving the Integrity Commissioner the mandate to accept complaints about Members of Council not only from other Members but also and most importantly from the public at large.

A complaint investigation and reporting process which gives due consideration to issues of fairness and privacy is in the process of being created.

Proposed Legislative Changes

In Ontario, Municipal Integrity Commissioners receive their powers pursuant to provincial legislation. Manitoba does not yet have similar legislative provisions. Accordingly, part of the Integrity Commissioner's work will involve working with the Public Service and Legal Services to make recommendations to Council for amendments to be sought to The City of Winnipeg Charter. These amendments will relate to the Integrity Commissioner's mandate and role, including granting investigative powers to the Integrity Commissioner and identifying appropriate sanctions should a Member of Council be found to have breached the Code of Conduct.

First Year's Priorities

During the first months of this term the Integrity Commissioner will be focused on activities which will include:

  • establishing how the Commissioner’s operations will be carried out;

  • becoming fully conversant and expert with relevant policies, procedures and by-laws applicable to Members of Council including the existing Code of Conduct and with relevant legislation including The Municipal Council Conflict of Interest Act;

  • examining the nature and extent of the Integrity Commissioner's jurisdiction in the context of the laws of Manitoba generally;

  • making recommendations to Council regarding the establishment of a new Code of Conduct including conducting a cross jurisdictional analysis of best practices in other jurisdictions;

  • establishing a Complaint Protocol; and

  • making recommendations to Council regarding changes to be sought to The City of Winnipeg Charter to enhance the authority of the Integrity Commissioner.

Your patience will be required while standards and processes are established which will allow the mandate of the Integrity Commissioner to be fulfilled in the most appropriate and effective way.

Update as of July 2017

My official duties as Integrity Commissioner commenced on April 1, 2017.

In the six weeks leading up to that date I spent many hours studying the ethics regimes of various levels of government in other jurisdictions in Canada and the United States and made contact with experts in the field of government ethics.

I also spoke with a number of municipal Integrity Commissioners, both past and present, across Canada, all of whom were generous with their time and sharing of expertise and experience.

As a result, I have made valuable connections within the Canadian municipal ethics community and was invited to speak at the Municipal Integrity Commissioners of Ontario annual conference in May of this year.  A copy of the power point presentation I gave to that conference, describing Winnipeg’s new ethics regime, can be found on this website.

In addition to attending the Municipal Integrity Commissioners of Ontario conference in May, I attended the annual conference of the Canadian Association of Programs in Public Administration which was held in Winnipeg this year and I joined a number of organizations whose focus is government ethics and public administration.

Establishing Professional Relationships with City Council

Once my official duties began, I spent a good part of the months of April and May meeting on an individual basis with each Member of City Council including the Mayor and 15 Councillors.  This allowed me to establish relationships with Council Members, to share my views about how I intend to perform the mandate Council has given me, and to hear from Council Members as to their needs and concerns regarding the ethical framework in which they perform their duties.

These meetings were a crucial step in establishing the necessary understanding with Council Members about our respective roles, keeping in mind that one of the most important aspects of the work performed by an Integrity Commissioner is the ability to provide advice on a pro-active basis so as to prevent breaches of ethical conduct.

In order to become knowledgeable about the work of City Council and the accountability framework which currently applies to Members of Council, I met with the Provincial Ombudsman, the City Auditor, executive assistants for Members of City Council, the City Solicitor and the City Clerk.

I also met with the Province’s Minister of Indigenous and Municipal Relations in order to discuss proposed amendments to The City of Winnipeg Charter and The Municipal Act which would give the role of the Integrity Commissioner more authority, create sanctions for breaches of ethical conduct on the part of Members of Council and enhance the ethics regime for municipalities in the Province, generally.

Lobbyist Registry

Since assuming the role of Integrity Commissioner, I have been formally appointed by Council to be the Lobbyist Registrar, overseeing the City’s Voluntary Lobbyist Registry.  Accordingly, I have met with the Provincial Lobbyist Registrar to compare processes.  I am available to answer questions from individuals or organizations with respect to whether they fall within the definition of “lobbyist” under the new regime now in place for the City.

Communication with the Public and Complaints

Since starting in this position, I have communicated with a number of members of the public to answer specific questions and provide information about my role and the ethics framework for City Council, generally.  With respect to individuals who indicated they wish to file complaints, I have confirmed that once Council has approved my recommendations for a Complaint Protocol I will be able to accept complaints that will then be addressed in accordance with the process set out in that document.

New Code of Conduct and Complaint Protocol

Consistent with the mandate I received from Council, I have conducted an extensive cross-jurisdictional analysis of the codes of conduct and the complaint investigation processes in other jurisdictions in order to draft a new Code of Conduct and a process for receiving, investigating and reporting on complaints.

I am currently working with Members of Council to finalize that Code and Complaint Protocol.  I hope to provide Council with a report containing my final recommendations for the approval of the new Code of Conduct and Complaint Protocol in October of this year.

Independent Opinion Regarding Conflicts of Interest

When Council voted on whether to appoint me as Integrity Commissioner, four Members of Council declared that they had a conflict such that they recused themselves from voting.

For the sake of clarity I retained the services of Greg Levine, who is a recognized authority on municipal ethics regimes in Canada to provide me with his independent opinion as to whether there were, in fact, conflicts of interest regarding my relationship with those Members of Council and which would prevent me from performing my mandate with respect to those Members.

A link to Mr Levine's opinion is included in the right hand column of this page, under the heading 'Reports'.

Mr Levine concluded that no such conflicts exist.

In his view, while everyone involved acted out of an abundance of caution, the matters disclosed do not constitute conflicts of interest.

He concludes his report by saying: "The City and the Commissioner are entering an exciting new phase of the development of Winnipeg's ethics system. They should do so unburdened by the disclosures of "potential" conflicts which this report has discussed."

Complaint Process

The Integrity Commissioner will be accepting complaints once a Complaint Protocol has been established and approved by Council. Establishing this Complaint Protocol is a priority. It is the intention that the Complaint Protocol will be in place by the fall of this year.

Your patience is appreciated.

Voluntary Lobbyist Registry

The Integrity Commissioner has been designated as the Registrar for the Voluntary Lobbyist Registry approved by Council on April 26, 2017. In this capacity, the Integrity Commissioner is available to answer questions and take comments from members of the public with respect to the Registry.

Lobbyist Registries can be complex and detailed. The current Voluntary Lobbyist Registry of the City of Winnipeg is a simplified version of the registry that exists in other jurisdictions. The Integrity Commissioner is responsible for further review and changes of the Registry process, and will be recommending changes to Council with respect to The City of Winnipeg Charter, in consultation with the City Solicitor, related to this process.

For more information on the Voluntary Lobbyist Registry or to register visit the Voluntary Lobbyist Registry webpage.

Education and Resources
Biography of the Integrity Commissioner


Called to the Bar in 1986, Sherri Walsh is a partner with the law firm Hill Sokalski Walsh Olson LLP. Ms. Walsh’s practice covers virtually all areas of civil litigation with an emphasis on human rights and constitutional law, Indigenous law, employment law, securities and insurance litigation, and administrative law. She has appeared at all levels of court in Manitoba and before the Supreme Court of Canada. Ms. Walsh is frequently retained to conduct investigations for corporations and institutions involving respectful workplace issues. She participates in and conducts mediations and arbitrations and recently issued an arbitration decision under the Manitoba Framework Agreement for Treaty Land Entitlement. She has also been frequently retained in criminal law matters to protect the privacy rights of victims of sexual assault, pursuant to the provisions of the Criminal Code.


Ms. Walsh is the Chief Adjudicator under The Human Rights Code (Manitoba) having been appointed to that position since its creation in 2012.

From 2011 to 2013, Ms. Walsh acted as Commission Counsel to The Honourable Ted Hughes when he presided over the Phoenix Sinclair Inquiry. This public inquiry was established by the Province of Manitoba to examine the circumstances surrounding the death of an Indigenous child who had received services from the provincial child welfare system.

Ms. Walsh is serving a second three year appointment as a Hearing Panel Chair for discipline hearings for the Mutual Fund Dealers Association Prairie Regional Council.

From 2001-2011, Ms. Walsh sat as a part-time Chair of the Appeal Commission for the Workers Compensation Board of Manitoba, representing the public interest.


For eight years, Ms. Walsh taught Introduction to Civil Procedure to 2nd year students at the Faculty of Law, University of Manitoba. She has been frequently asked by the Law Society of Manitoba to chair or present Continuing Education Seminars and often serves as an instructor for the Bar Admission course. She was a coach for the Manitoba Faculty of Law School's 2014 team for the Laskin Moot Competition – a bilingual national moot court competition.

Ms. Walsh also taught a course entitled "Poverty and the Law" to students in the Department of Urban and Inner Studies at the University of Winnipeg, in 2014 and 2015.


The value of Ms. Walsh’s work particularly in the areas of social justice and human rights has been recognized by her peers and others.

On January 28, 2016 – the 100th Anniversary of some women in Manitoba receiving the right to vote, Ms. Walsh was awarded the inaugural Nellie award – in recognition of her work to promote social justice, human rights and the rights of women and girls, in Manitoba.

In 2013 she was recognized as the Manitoba Female Litigator of the year by Benchmark Litigation Canada and has consistently been recognized as a Litigation Star by that publication every year

In 2006, she was named a "human rights star" by the Manitoba League of Persons with Disabilities.

In 2000 she received the inaugural Manitoba Human Rights Commitment Award co-sponsored by the Canadian Human Rights Commission, the Manitoba Human Rights Commission and the Community Legal Education Association in recognition of achievements in advancing human rights through the justice system.

In 1999 she received the Manitoba Bar Association's Award for Pro Bono work.

Other Professional Involvement

Ms. Walsh is consistently appointed by the Benchers of the Law Society of Manitoba to sit on various standing and ad hoc committees of the Law Society, including the Complaints Investigation Committee, the Discipline Committee, the Committee on Practice and Ethics, and the President’s Special Committees on the Independence of the Legal Profession, Emerging Issues for the Legal Profession, Trust Safety and Entity Regulation.

She is a member of a number of professional associations including the Canadian Bar Association, Manitoba Bar Association, Association des juristes d’expression française du Manitoba, the International Commission of Jurists (Canadian section) and the ADR Institute of Canada / Institut d’Arbitrage et de Médiation du Canada Inc.

Community Involvement

Outside the practice of law, Ms. Walsh has sat on the Boards of a number of non-profit organizations.

She currently sits as a Director on the Boards of the University of Winnipeg Foundation and the Manito Ahbee Festival.

She is a longtime volunteer with Winnipeg Harvest - a non-profit food bank and served as Chair of its Board for four years.

Last update: July 28, 2017