Deloitte Final English

8/7/2019 Deloitte Final English

1/24

Review of Closed

Operational FilesOffice of Public SectorIntegrity Commissioner

March 31, 2011Confidential


2/24

Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files i

Table of contents

1 Introduction and Background .................................................................................................................. 11.1 Introduction and Objective ......................................................................................................... 11.2 Background................................................................................................................................ 11.3 Mandate ..................................................................................................................................... 1

2 Executive Summary ................................................................................................................................ 32.1 Overall results of file review ....................................................................................................... 32.2 Overall summary of issues identified ......................................................................................... 3

3 Scope of Review ..................................................................................................................................... 44 Our understanding of the types of complaints and the OPSIC process for handling complaints .......... 5

4.1 Disclosure of alleged wrongdoing by public servants................................................................ 54.2 Disclosure of alleged wrongdoing pursuant to Section 33 of the PSPDA ................................. 64.3 Complaints of alleged reprisal ................................................................................................... 7

5 Discussions of Findings .......................................................................................................................... 95.1.1 Files covered by our review ................................................................................................ 95.1.2 Completeness of files .......................................................................................................... 9

5.2 Distribution of files reviewed ...................................................................................................... 95.3 Approach and methodology ....................................................................................................... 9

5.3.1 Applicable Act ................................................................................................................... 105.3.2 Other applicable guidelines, rules and regulations ........................................................... 10

5.4 Overall results of our review .................................................................................................... 105.4.1 Results by type of file ........................................................................................................ 115.4.2 Result by fiscal year .......................................................................................................... 12

5.5 Discussion of types of issues identified ................................................................................... 135.5.1 Not all issues reported to OPSIC were dealt with ............................................................. 13 5.5.2 Lack of documentation to support the conclusions ........................................................... 135.5.3 Lack of analysis to support the conclusions ..................................................................... 135.5.4 No admissibility analysis ................................................................................................... 135.5.5 New information provided to OPSIC and file was not re-evaluated .................................. 14


3/24

Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files ii

5.5.6 Decision letter signed by Registrar ................................................................................... 145.5.7 Other types of issues ........................................................................................................ 14

Appendix A List of OPSIC Closed Operational Files Reviewed .............................................................. 15


4/24

Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files iii

Confidential

March 31, 2011

Mr. Mario DionInterim Public Sector Integrity CommissionerOffice of Public Sector Integrity Commissioner60 Queen Street, 7th Floor

Ottawa, ON K1P 5Y7

Subject: Review of closed operational files

Dear Mr. Dion:

Attached is our report setting out the findings from our review.

Our findings are based on procedures undertaken as described in Section 3 of this report and are subject tothe restrictions in scope as set out therein.

Should you have any questions or concerns, please do not hesitate to contact me at 613-751-5378.

Yours very truly,

Original report signed

Gary Timm, CAIFA, CFEPartner, Financial Advisory

Deloitte & Touche LLP

Enclosure

Deloitte & Touche LLP100 Queen Street

Suite 800Ottawa ON K1P 5T8

Tel: 613-751-5378Fax: 613-563-2244www.deloitte.ca


5/24

Deloitte & Touche LLP and affiliated entities. OPSIC: Review of closed operational files 1

1Introduction and background

1.1 Introduction and objective

Deloitte & Touche LLP (Deloitte) was retained by the Office of the Public Sector Integrity Commissionerof Canada (OPSIC) to perform a review of closed disclosure of wrongdoing and reprisal complaints filesin order to determine whether they were dealt with in a manner consistent with the requirements of thePublic Servants Disclosure Protection Act(PSDPA) and with applicable legal1, investigative andadministrative decision-making standards. The purpose of the review is to identify any possible issues orerrors in process or fact in the files in relation to the criteria as set out in Section 1.3.

1.2 Background

OPSIC has the mandate to establish a safe, confidential and independent mechanism for public servantsor members of the public to disclose potential wrongdoing in the federal public sector. It also protectspublic servants from reprisal for making such disclosures or cooperating in investigations. OPSICs goalis to enhance public confidence in our public institutions and in the integrity of public servants. In carryingout its mandate, the Commissioner is required to submit an annual report to Parliament.

On October 20, 2010, OPSIC announced that Christine Ouimet, the Public Sector Integrity Commissioner,retired from Public Service, effective October 18, 2010.

On December 9, 2010, the Auditor General (AG) of Canada issued a report related to a performanceaudit of OPSIC. With regard to the performance of PSICs mandated function, the AG reported thefollowing:

In our view, the allegations against the Commissioner concerning the improperperformance of her mandated functions are founded. During the period covered by ouraudit, procedures for conducting investigations were not finalized or implemented. Wealso found that, in many cases, decisions to refuse to investigate, or to dismissdisclosures of wrongdoing and complaints of reprisal were not supported by either thenature of work performed, the documentation on file, or both. It is also our viewthat decisions by the Commissioner to refuse to investigate certain complaints of reprisalon the basis that she could not conclude that an act of reprisal had occurred extendedbeyond her responsibilities under the PSDPA. Again, we considered information gatheredfrom multiple sources in the course of our audit in arriving at this conclusion.

Mr. Mario Dion was appointed Interim Commissioner in December 2010. Mr. Dion initiated acomprehensive third party review of all closed files from the inception of OPSIC in 2007 to December 20,

2010. Following a competitive procurement process, Deloitte was retained to undertake the third partyreview.

1.3 Mandate

The Deloitte engagement consisted of a review and assessment of all closed disclosure and reprisalcomplaint files, totalling 221 files. For each file, Deloitte was asked to review and assess the followingfactors:

1 Our work and the resulting report do not constitute a legal opinion regarding the PSPDA, nor do they represent such an opinion inany way.


6/24


1. Determine the issues and allegations identified (reported to PSIC) in the disclosure or reprisalcomplaint;

2. Assess whether the analysis conducted by PSIC addresses all relevant issues and allegations;

3. Assess whether the analysis conducted by PSIC provides a rationale or reasons for therecommendations in accordance with the requirements of the PSPDA;

4. Assess whether the decision rendered addresses the relevant issues and allegations;

5. Assess whether the decision rendered meets the requirements of the PSDPA; and

6. Assess whether there is sufficient documentation on file to support the analysis,recommendations and the decision of the Commissioner.

OPSIC requested that we conduct a process review and assess closed files in relation to the six specificquestions or factors, as noted above. We were not requested by OPSIC to review and assess thespecifics of the case analysis work performed and the appropriateness, adequacy and completeness ofthe investigative steps undertaken by OPSIC personnel.

We understand that OPSIC has retained the services of a Special Advisor to provide the InterimCommissioner with recommendations regarding possible corrective measures for any file where an issuerelating to one or more of the factors above is identified.


7/24


2Executive summary

2.1 Overall results of file review

Based on our review of the 221 closed operational files, we identified 70 files that have issues in relationto the factors that were reviewed and assessed as defined in Section 1.3 of this report. We did not identifyissues in relation to the factors that were reviewed and assessed with the remaining 151 files.

Table 1: Summary of Files Reviewed, by Fiscal Year

Nature of deficiency FY2007/2008 FY2008/2009 FY2009/2010 FY2010/2011 Tota l

Issues identified 34 18 16 2 70

No issues identified 43 47 44 17 151

Total number of files 77 65 60 19 221

Percentage of files where issues

were identified44% 28% 27% 11% 32%

Number of files

2.2 Overall summary of issues identified

The following chart summarizes the types of issues identified in the files reviewed by fiscal year:

Table 2: Summary of Issues Identified, by Fiscal Year

Nature of issue FY2007/2008 FY2008/2009 FY2009/2010 FY2010/2011 Total

Not all issues reported to OPSIC

were dealth with14 5 4 2 25

Lack of documentation to support

the conclusions19 4 7 2 32

Lack of analysis to support the

conclusions12 8 10 1 31

No admissibility analysis 4 4 4 12

New information provided to OPSIC

and file was not re-evaluated4 1 5

Decision letter signed by Registrar 2 1 3

Other types of issues 1 4 1 6

Total number of issues identified 56 27 26 5 114

Total number of files where

issues were identified [1]34 18 16 2 70

Number of files where issues were identified

[1] Due to specific files containing multiple types of issues, the total number of files identified as having issues is less than thetotal number of issues identified.


8/24


3Scope of review

Our review covered the period from inception of OPSIC in 2007 to December 20, 2010 (the ReviewPeriod) and was limited to the issues described in this report. This period was selected based oninstructions from OPSIC.

Our review included 221 closed operational files as identified and provided to us by OPSIC. We havepresented a list of the specific files reviewed at Appendix A to this report.

Our procedures during the Review Period included a review of the available documentation contained inthe OPSIC closed files, as provided to us, along with processes, policies and procedures of OPSICrelevant to the issues. We have not undertaken interviews of the OPSIC personnel or third parties in

relation to these files.

In preparing the report, we specifically reviewed and/or relied upon the Public Servants DisclosureProtection Act, S.C.2005, C. 46, current to December 14, 2010, published by the Minister of Justice athttp://laws-lois.gc.ca

As previously noted, OPSIC requested that we conduct a process review and assess closed files inrelation to the six specific questions or factors, as outlined at Section 1.3 of this report. We were notrequested by OPSIC to review and assess the specifics of the case analysis work performed and of theappropriateness, adequacy and completeness of the investigative steps undertaken by OPSIC personnel.

We reserve the right, but will be under no obligation, to review this report, and if we consider it necessary,to revise our report in light of any information, which becomes known to us after the date of this report.

Our work does not constitute an audit as defined by the Canadian Institute of Chartered Accountants.Consequently, said work and the resulting report do not constitute an auditors opinion nor do theyrepresent such an opinion in any way.


9/24


4Our understanding of the types ofcomplaints and the OPSIC process

for handling complaints

In terms of complaints received by OPSIC, they include three categories:

1. Disclosure of alleged wrongdoing by public servants;

2. Disclosure of alleged wrongdoing pursuant to Section 33 of the PSPDA; and

3. Complaints of alleged reprisal.

Our understanding of each of these categories is described in the following sections.

4.1 Disclosure of alleged wrongdoing by public servants

Public Servants (as defined at Section 2 of the PSPDA) can disclose allegations of wrongdoing to OPSIC.The types of disclosures from public servants that OPSIC can investigate include the following types ofalleged wrongdoing2:

1. A contravention of any Act of Parliament or of the legislature of a province or any regulations

made under any such act;

2. A misuse of public funds or a public asset;

3. A gross mismanagement in the federal public sector;

4. An act or omission that creates a substantial and specific danger to the life, health or safety ofpersons, or to the environment, other than a danger that is inherent in the performance of theduties or functions of a public servant;

5. A serious breach of a code of conduct (established by Treasury Board or by an organization, asrequired by the PSPDA); and

6. Knowingly directing or counselling a person to commit a wrongdoing as defined in 1 to 5 above.

We understand that OPSICs review process for disclosures of alleged wrongdoing by public servants isas depicted in the following diagram.

2Public Servant Disclosure Protection Act (S.C. 2005, c. 46), section 8 wrongdoings.


10/24

Deloitte & Touche LLP and affiliated entiti

Although the state of the review proreview, the key processes reviewed

1. Receipt of the disclosure aOPSIC's Registrar. The disrequired to thoroughly revieanother mechanism that mi

2. Review of the admissibilityadvisor, reviews the informcould include consultationand law. A detailed admissiCommissioner, with a reco

3. Commissioner's decision file and admissibility reportinvestigation. A decision leproceed with an investigati

4.2 Disclosure of alleged

Section 33(1) of the PSPDA providwrongdoings related to the Public Sattention of OPSIC by individuals ot

The types of alleged wrongdoing thof this report (Disclosure of alleged

The distinction made at Section 33(

1. The Commissioner must ha

s. OPSIC: Review of clo

Source: OPSIC webs

cess has evolved since the inception of OPSIC, forwere as follows:

d initial assessment All disclosures are receivedloser may be contacted for clarification or additiona

w the disclosure. It is possible that the discloser willght address the issue more appropriately.

of the disclosure An analyst/investigator, with thetion presented to determine if further action is requiith subject-matter experts and research on relevant

bility report is submitted to the Commissioner, or tomendation to either proceed or to take no further a

The Commissioner or Deputy Commissioner reviewto determine if further action is needed, including latter is transmitted to the discloser indicating whethern.

rongdoing pursuant to Section 33 of th

s additional powers to OPSIC to investigate other aervice typically these are allegations of wrongdoinher than public servants.

t OPSIC can investigate are identical to those listewrongdoing by public servants).

1) of the PSPDA is that a two-part test must be met,

ve reason to believe that a wrongdoing has been co

ed operational files 6

te

he purpose of our

nd reviewed byl informationbe advised of

upport of a legalred. This reviewissues of policyhe Deputyction.

s the disclosurenching anor not OPSIC will

PSPDA

llegedg brought to the

at Section 4.2.1

namely that:

mmitted; and


11/24


2. The Commissioner must believe on reasonable grounds that the public interest requires aninvestigation.

If the above two-part test is met, we understand that OPSICs review process is identical to the processlisted at Section 4.2.1 of this report (Disclosure of alleged wrongdoing by public servants).

4.3 Complaints of alleged reprisalOPSIC has exclusive jurisdiction to investigate complaints of alleged reprisals. Current and former PublicServants (as defined at Section 2 of the PSPDA) can make a complaint to OPSIC if, because thecomplainant has made a protected disclosure or has, in good faith, cooperated to disclose allegations ofwrongdoing to OPSIC, the complainant has been subjected to alleged reprisal(s). Measures takenagainst current and former Public Servants which can represent a reprisal include the following:

1. A disciplinary measure,

2. The demotion of a public servant,

3. The termination of employment of a public servant, including, in the case of a member of theRoyal Canadian Mounted Police, a discharge or dismissal,

4. Any measure that adversely affects the employment or working conditions of the public servant;and

5. A threat to take any of the measures or directing a person to do so.

We understand that OPSICs review process for complaints of alleged reprisal for current and formerpublic servants is as depicted in the following diagram.


12/24

Deloitte & Touche LLP and affiliated entiti

Although the state of the review pro

review, the key processes reviewed

1. Receipt of the complaints oreprisal are received and reclarification or additional inf

2. Review of the admissibilityinformation to review a reprnot to deal with it. An anala recommendation to the Cshould be dealt with or not

3. Commissioner's decision

the complainant to indicatefor this decision.

s. OPSIC: Review of clo

Source: OPSIC websi

cess has evolved since the inception of OPSIC, for

were as follows:

f alleged reprisal and initial assessment All complviewed by OPSIC's Registrar. The complainant maormation required to thoroughly review the complain

of the complaint of alleged reprisal Once OPSIC hisal complaint, the Commissioner has 15 days to dest/investigator will prepare an admissibility analysisommissioner or Deputy Commissioner on whether ty OPSIC.

The Commissioner or Deputy Commissioner sends

whether they will deal with the complaint and, if not,

ed operational files 8

e

he purpose of our

ints of allegedbe contacted for

t.

as sufficientcide whether orin order to providee complaint

a written notice to

provide reason(s)


13/24


5Discussions of findings

5.1 Files subject to our review

5.1.1 Files covered by our review

Our review was limited to 221 closed operational files, as of December 10, 2010, as identified at AppendixA to this report. We have been advised by OPSIC that this list includes all files which have been closedsince the inception of OPSIC in 2007 to December 20, 2010.

Our review did not include files which had not been closed as of December 20, 2010 (i.e. files that werebeing assessed as to their admissibility and file for which investigations were being conducted by OPSIC).

5.1.2 Completeness of files

OPSIC was responsible for providing us the files to be reviewed. In order to ensure that the files werecomplete, and that we had access to all available information to review and assess the six specificquestions or factors, OPSIC representatives performed a review of electronic information contained in theOPSIC Case Management System (CMS), as well as other existing electronic information saved onOPSICs network.

Any additional information identified from a review of CMS and other electronic information was printed forour review and identified as additional information.

For cases where information appeared to be missing from the file based on the information reviewed, we

made further inquiries with OPSIC representatives in order to determine whether the information wasavailable or not before concluding on our review and assessment of the specific file.

5.2 Distribution of files reviewed

The 221 files covered by our review are categorized by file type as follows:

1. Disclosure of alleged wrongdoing by Public Servants 100 files

2. Disclosure of alleged wrongdoing pursuant to Section 33 of the PSPDA 55 files

3. Complaints of alleged reprisal 66 files

This summary of files by category may differ slightly from OPSICs categorization of these files as wehave reclassified a small number of files as a result of our review.

5.3 Approach and methodology

In order to conclude on each of the six factors to be reviewed and assessed for each of the closedoperational files, we completed the following:

1. We requested the documentation for each specific file from OPSIC, which we understandincluded all information available at OPSIC as outlined at Section 5.1.2. The majority of each ofthe files comprised a single filing folder. Some of the closed files comprised multiple filing folders,or had additional documents contained in binders, accordion files or boxes.


14/24


2. The files were reviewed and key information captured in a template specific to the type of file (i.e.,disclosures by public servants, Section 33 disclosures and complaints of reprisal). Thesetemplates were based on the relevant sections of the PSPDA. The information captured enabledthe review and assessment of the six factors outlined at Section 1.3 for each file reviewed.

3. The overall results of the individual reviews were compiled. If the review template for a filecontains a no answer to one or more of the factors #2 to 6 being reviewed, it was identified has

having an issue.

4. The issues identified were grouped by their type and nature in order to provide OPSIC with anoverall summary of issues identified and their frequency within the population of files reviewed.

5.3.1 Applicable Act

Our work was completed pursuant to the provisions of the PSDPA. We reviewed the PSPDA andobtained an understanding of specific provisions from OPSIC in order to identify which sections of thePSPDA were applicable to our review of the six specific factors. Our review of each OPSIC file wasbased on our understanding of the PSPDA.

Our work and the resulting report do not constitute a legal opinion regarding the PSPDA, nor do they

represent such an opinion in any way.

5.3.2 Other applicable guidelines, rules and regulations

Certain of the files reviewed included determination, recommendation and decisions regarding other Actsof Parliament. As an example, OPSIC may have refused to investigate an allegation of wrongdoing ifOPSIC determined that another Act of Parliament was better suited for the subject-matter of theallegations. In such cases, we have not reviewed the details of these guidelines, rules, regulations andActs of Parliament. Rather, we have reviewed the content of the file and assessed if a rationale existedfor OPSICs determination that these guidelines, rules, regulations and Acts of Parliament were bettersuited to deal with the subject-matter of the allegations.

5.4 Overall results of our review

Based on our review of the 221 closed operational files, we identified 70 files that have issues in relationto the factors that were reviewed and assessed as defined in Section 1.3 of this report. We did not identifyissues in relation to the factors that were reviewed and assessed with the remaining 151 files.


15/24


The following chart summarizes the types of issues we have identified in the files reviewed:

Table 3: Summary of Issues Identified

Nature of issueNumber of files where

issue was identified

Not all issues reported to OPSIC were dealth with 25

Lack of documentation to support the conclusions 32

Lack of analysis to support the conclusions 31

No admissibility analysis 12

New information provided to OPSIC and file was not

re-evaluated5

Decision letter signed by Registrar 3

Other types of issues 6

Total number of issues identified 114

Total number of files where issues were identified [1] 70

[1] Due to specific files containing multiple types of issues, the total number of files identified ashaving issues is less than the total number of issues identified.

We have provided OPSIC with the specifics of our findings. As previously noted, we understand thatOPSIC has retained the services of a Special Advisor to provide the Interim Commissioner withrecommendations regarding possible corrective measures for any file where one or more issues havebeen identified.

5.4.1 Results by type of file

The table below summarizes a breakdown of the results of our review of the 221 closed operational files,by type of file, separating files where issues have been identified from files where no issues wereidentified in relation to the factors that were reviewed and assessed.

Table 4: Summary of Files Reviewed, by Type of File

Disclosure from

public servant

Section 33

disclosure

Complaint of

reprisalTotal

Issues identified 27 20 23 70

No issues identified 73 35 43 151

Total 100 55 66 221

Number of files


16/24


The following chart summarizes the types of issues identified in the files reviewed by the three categoriesof files:

Table 5: Summary of Issues Identified, by Type of File

Nature of issueDisclosure from

public servant

Section 33

disclosure

Complaint of

reprisal

Total

Not all issues reported to OPSIC

were dealth with10 8 7 25

Lack of documentation to support

the conclusions13 8 11 32

Lack of analysis to support the

conclusions12 6 13 31

No admissibility analysis 8 2 2 12

New information provided to OPSIC

and file was not re-evaluated2 3 5

Decision letter signed by Registrar 1 2 3

Other types of issues 4 2 6

Total number of issues identified 48 30 36 114

Total number of files where

issues were identified [1]27 20 23 70

Number of files where issues were identified

[1] Due to specific files containing multiple types of issues, the total number of files identified as having issues is less thanthe total number of issues identified.

5.4.2 Result by fiscal year

The table below is a summary of the results of our review of the 221 closed operational file, by fiscal year(year-end date being March 31), separating files where issues have been identified from files where noissues were identified in relation to the factors that were reviewed and assessed.

Table 6: Summary of Files Reviewed, by Fiscal Year

FY2007/2008 FY2008/2009 FY2009/2010 FY2010/2011 Total

Issues identified 34 18 16 2 70

No issues identified 43 47 44 17 151

Total 77 65 60 19 221

Number of files


17/24


18/24


5.5.5 New information provided to OPSIC and file was not re-evaluated

We have identified five (5) instances where new or additional information was provided to OPSIC but,based on specific comments included in correspondence to the discloser or complainant or a lack thereof,it does not appear that OPSIC reviewed the additional information or re-evaluated the status of the file.

5.5.6 Decision letter signed by Registrar

We have identified three (3) instances where a decision letter was signed by the registrar. This practiceappears to be contrary to Section 24(3) and 25(1)(g) of the PSPDA.

Section 24(3) of the PSPDA states that:

If the Commissioner refuses to deal with a disclosure or to commence an investigation,he or she must inform the person who made the disclosure, or who provided theinformation referred to in section 33, as the case may be, and give reasons why he orshe did so.

And Section 25(1) of the PSPDA states that:

The Commissioner may delegate to any employee in the Office of the Public SectorIntegrity Commissioner any of his or her powers and duties under this Act, except

(g) the power in section 24 to refuse to deal with a disclosure or to commence aninvestigation, the power in that section to cease an investigation and the duty in thatsection to provide reasons;

5.5.7 Other types of issues

We have also noted instances of the following issues:

1. PSIC indicated that a matter would be referred to another agency but there is no evidence on filethat this was done.

2. File received in error and only referred to the Office of the Auditor General after seven weeks hadgone by, without notifying the discloser.

3. On two files, OPSIC did not address the question of whether OPSIC should investigate adisclosure against its own employee, or whether this should be referred to the Office of theAuditor General.

4. Lack of evidence that OPSIC notified the discloser of its decision to undertake an investigation.

5. Lack of an indication that a separate file was opened to deal with a portion of the information

received (i.e. no indication that a reprisal file was opened).


19/24


Appendix A

List of OPSIC closed operational files

reviewed

We have reviewed the following OPSIC closed operational files. The files numbers are based on thenumbering system utilized by OPSIC in their case management system.

1. PSIC-2007-D-015

2. PSIC-2007-R-016

3. PSIC-2007-R-038

4. PSIC-2007-D-064

5. PSIC-2007-S33-068

6. PSIC-2007-S33-072

7. PSIC-2007-R-078

8. PSIC-2007-S33-089

9. PSIC-2007-S33-094

10. PSIC-2007-S33-102

11. PSIC-2007-D-107

12. PSIC-2007-S33-108

13. PSIC-2007-S33-130

14. PSIC-2007-R-135

15. PSIC-2007-D-136

16. PSIC-2007-R-140

17. PSIC-2007-D-141

18. PSIC-2007-S33-145

19. PSIC-2007-R-147

20. PSIC-2007-D-149

21. PSIC-2007-R-151

22. PSIC-2007-S33-153

23. PSIC-2007-S33-155

24. PSIC-2007-R-156

25. PSIC-2007-S33-157

26. PSIC-2007-D-162

27. PSIC-2007-S33-163

28. PSIC-2007-D-164

29. PSIC-2007-D-168

30. PSIC-2007-R-172

31. PSIC-2007-D-173

32. PSIC-2007-D-175

33. PSIC-2007-D-177

34. PSIC-2007-R-178

35. PSIC-2007-R-180

36. PSIC-2007-S33-184

37. PSIC-2007-D-185

38. PSIC-2007-D-187

39. PSIC-2007-D-190

40. PSIC-2007-D-191


20/24


41. PSIC-2007-D-193

42. PSIC-2007-R-198

43. PSIC-2007-D-200

44. PSIC-2007-S33-203

45. PSIC-2007-R-204

46. PSIC-2007-R-207

47. PSIC-2008-D-208

48. PSIC-2007-D-209

49. PSIC-2007-D-210

50. PSIC-2007-R-213

51. PSIC-2007-S33-214

52. PSIC-2007-R-215

53. PSIC-2007-D-216

54. PSIC-2007-D-224

55. PSIC-2007-R-225

56. PSIC-2007-R-226

57. PSIC-2007-S33-228

58. PSIC-2007-D-240

59. PSIC-2007-A-243

60. PSIC-2007-S33-249

61. PSIC-2007-S33-251

62. PSIC-2007-R-252

63. PSIC-2007-R-260

64. PSIC-2008-D-269

65. PSIC-2007-R-271

66. PSIC-2007-D-281

67. PSIC-2007-D-282

68. PSIC-2007-D-286

69. PSIC-2007-R-287

70. PSIC-2007-D-291

71. PSIC-2007-D-296

72. PSIC-2007-A-299

73. PSIC-2007-D-305

74. PSIC-2007-R-310

75. PSIC-2007-S33-312

76. PSIC-2008-S33-325

77. PSIC-2008-S33-326

78. PSIC-2008-D-328

79. PSIC-2008-D-329

80. PSIC-2008-A-333

81. PSIC-2007-R-337

82. PSIC-2008-S33-338

83. PSIC-2008-D-345

84. PSIC-2008-D-350

85. PSIC-2008-D-351

86. PSIC-2008-D-353

87. PSIC-2008-D-354

88. PSIC-2008-D-362

89. PSIC-2007-A-366

90. PSIC-2008-D-368

91. PSIC-2008-R-370

92. PSIC-2008-S33-376

93. PSIC-2008-D-382

94. PSIC-2008-D-384

95. PSIC-2008-R-385

96. PSIC-2008-R-387

97. PSIC-2008-D-388

98. PSIC-2008-D-389


21/24


99. PSIC-2008-R-391

100. PSIC-2008-S33-398

101. PSIC-2008-R-400

102. PSIC-2008-D-403

103. PSIC-2008-S33-407

104. PSIC-2008-D-408

105. PSIC-2008-R-411

106. PSIC-2008-R-417

107. PSIC-2008-D-427

108. PSIC-2008-D-438

109. PSIC-2008-R-441

110. PSIC-2008-D-442

111. PSIC-2008-D-443

112. PSIC-2008-D-452

113. PSIC-2008-R-460

114. PSIC-2008-D-462

115. PSIC-2008-D-464

116. PSIC-2008-S33-465

117. PSIC-2008-R-470

118. PSIC-2008-R-476

119. PSIC-2008-D-477

120. PSIC-2008-D-478

121. PSIC-2008-D-479

122. PSIC-2008-D-480

123. PSIC-2008-R-483

124. PSIC-2008-A-485

125. PSIC-2008-D-487

126. PSIC-2008-R-490

127. PSIC-2008-R-500

128. PSIC-2008-D-502

129. PSIC-2008-R-503

130. PSIC-2008-R-509

131. PSIC-2008-D-510

132. PSIC-2008-S33-511

133. PSIC-2008-D-513

134. PSIC-2008-D-514

135. PSIC-2008-D-516

136. PSIC-2008-D-518

137. PSIC-2008-R-521

138. PSIC-2008-D-523

139. PSIC-2008-R-524

140. PSIC-2008-D-525

141. PSIC-2008-D-526

142. PSIC-2008-R-527

143. PSIC-2008-D-528

144. PSIC-2009-D-542

145. PSIC-2009-R-544

146. PSIC-2009-S33-546

147. PSIC-2009-S33-549

148. PSIC-2009-D-560

149. PSIC-2009-D-561

150. PSIC-2009-D-562

151. PSIC-2009-S33-563

152. PSIC-2009-D-564

153. PSIC-2009-S33-595

154. PSIC-2009-S33-600

155. PSIC-2009-D-601

156. PSIC-2009-S33-602


22/24


157. PSIC-2009-D-614

158. PSIC-2009-R-620

159. PSIC-2009-S33-635

160. PSIC-2009-R-636

161. PSIC-2009-D-638

162. PSIC-2009-S33-640

163. PSIC-2009-R-641

164. PSIC-2009-S33-645

165. PSIC-2009-S33-653

166. PSIC-2009-R-654

167. PSIC-2009-D-661

168. PSIC-2009-D-664

169. PSIC-2009-S33-669

170. PSIC-2009-D-685

171. PSIC-2009-S33-686

172. PSIC-2009-D-690

173. PSIC-2009-D-695

174. PSIC-2009-R-701

175. PSIC-2009-S33-706

176. PSIC-2009-D-710

177. PSIC-2009-R-724

178. PSIC-2009-R-725

179. PSIC-2009-D-726

180. PSIC-2009-D-728

181. PSIC-2009-D-729

182. PSIC-2009-R-733

183. PSIC-2009-D-741

184. PSIC-2009-D-745

185. PSIC-2009-R-749

186. PSIC-2009-S33-750

187. PSIC-2009-D-752

188. PSIC-2009-D-754

189. PSIC-2009-S33-756

190. PSIC-2009-R-767

191. PSIC-2009-D-770

192. PSIC-2009-S33-772

193. PSIC-2009-R-782

194. PSIC-2009-R-783

195. PSIC-2009-S33-786

196. PSIC-2009-D-787

197. PSIC-2009-R-792

198. PSIC-2009-D-794

199. PSIC-2009-S33-798

200. PSIC-2009-D-799

201. PSIC-2009-S33-801

202. PSIC-2009-S33-802

203. PSIC-2010-R-829

204. PSIC-2010-D-830

205. PSIC-2010-D-833

206. PSIC-2010-R-844

207. PSIC-2010-R-852

208. PSIC-2010-D-856

209. PSIC-2010-S33-864

210. PSIC-2010-D-867

211. PSIC-2010-D-874

212. PSIC-2010-R-887

213. PSIC-2010-R-895

214. PSIC-2010-R-905


23/24


215. PSIC-2010-D-909

216. PSIC-2010-S33-914

217. PSIC-2010-D926

218. PSIC-2010-R-953

219. PSIC-2010-D-961

220. PSIC-2010-D-993

221. PSIC-2010-R-1005


24/24

www.deloitte.ca

Deloitte, one of Canada's leading professional services firms, provides audit, tax, consulting, and financial advisory servicesthrough more than 7,600 people in 57 offices. Deloitte operates in Qubec as Samson Blair/Deloitte & Touche s.e.n.c.r.l.Deloitte & Touche LLP, an Ontario Limited Liability Partnership, is the Canadian member firm of Deloitte Touche Tohmatsu Limited.

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network ofmember firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed

Documents

Deloitte Final English