Township of Brock Integrity Commissioner, Guy Giorno

Citation: Miller v. Bath-Hadden, 2020 ONMIC 12 Date: October 13, 2020

Report on Complaint

Notice: Municipal Integrity Commissioners provide investigation reports to their respective municipal council and, in most cases, make recommendations for imposition of penalty or other remedial action to the municipal Council. Therefore, reference should be made to the minutes of each particular municipal council to obtain information about the particular council's consideration of each report. When possible, a link to the relevant municipal council minutes is provided.

Please find below the link to the corresponding council decision. https://calendar.townshipofbrock.ca/meetings/Detail/2020-11-23-1830-Council-Session-Twelve/63f3ca5c-7a28-4898-89f8-ac8d009149d9 (see Council Minutes, Session Twelve, November 23, 2020, Resolution Number 34-12, page 10 of 13)

TABLE OF CONTENTS

The Complaint 3

Summary. 3

Background. 3

Process Followed. 6

Positions of the Parties. 8

Positions of parties on preliminary issue of meeting conduct 8

Positions of parties on preliminary issue of harassment complaint by someone who did not experience it 8

Position of the Complainant (Therese Miller) 9

Position of the Respondent (Mayor Bath-Hadden) 10

Position of the Complainant in Reply. 10

Findings of Fact 11

Issues and Analysis. 11

A. Preliminary Issue: Jurisdiction of Integrity Commissioner to enforce section 4.0 (Council/ Committee Meeting Conduct) 12

B. Preliminary Issue: Jurisdiction of Integrity Commissioner to consider a harassment complaint made by someone who is not the individual alleged to have experienced the harassment 13

C. Did the Feb. 7 language contravene section 4.0 by using “offensive words”?. 14

D. Did the Feb. 7 language contravene section 14.0, specifically the Ontario Human Rights Code section?. 14

E. Did the conduct depicted in the Feb. 1 photo contravene section 14.0, specifically the Harassment & Violence in the Workplace Policy section?. 15

RecommendationS.. 15

Content 16

Appendix. 17

The Complaint

1. This report concludes a brief inquiry into a complaint related to a February 1 photograph and a February 7 meeting.

2. Ms Therese Miller (Complainant) alleges that Mayor Debbie Bath-Hadden (Respondent) contravened the Code of Conduct for Members of Council¹ by using offensive and discriminatory language during the February 7 Committee of the Whole meeting.

3. The Complainant also alleges that a February 1 group photograph posted on Facebook shows the Respondent engaged in harassment of the Regional Chair.

Summary

4. After hearing from the parties I have exercised my discretion to discontinue the investigation into the group photograph. I took into account the fact that nobody in the photograph, including the Regional Chair, had complained.

5. The Respondent acknowledges that it was wrong to utter the offensive and discriminatory term. She has apologized publicly.

6. The Respondent was right to apologize. I agree that use of the expression was inappropriate.

Background

7. The Beaverton Lions Club Winter Carnival 2020 was held February 1. Afterward, four Facebook users, including the Club itself, posted a total of 31 event photos on the Club’s Facebook page.²

8. The Mayor (Respondent) posted seven of these photos, including a group photograph of the Mayor, the Regional Chair, the Deputy Mayor, the federal Member of Parliament and the Mayor of Uxbridge.

9. When Ms Miller (Complainant) saw the group photograph that the Mayor had posted, she felt that the Mayor’s position was “totally inappropriate.” The Complainant describes the photo as showing the Mayor sitting on the Regional Chair’s lap with her arm around the Regional Chair. The Respondent states that she was not sitting on the Regional Chair’s lap.

10. The Complainant says she is able to identify the Regional Chair in the photograph because she served on Township Council from 2004 to 2018.

11. The Complainant takes the position that the conduct shown in the photograph amounts to harassment of the Regional Chair by the Mayor.

12. The only complaint filed in relation to this photograph is that of Ms Miller. Nobody complained who was actually present when the photo was taken.

13. The Complainant further alleges that the Mayor contravened the Code of Conduct when she used the term “Indian giver” during the February 7 meeting of Council’s Committee of the Whole. The Mayor directed the comment to the Fire Chief during a discussion of the Fire Department budget.

14. The video recording of the meeting contains the following exchange, as part of a discussion about reviewing and updating the Township’s emergency plan:³

Councillor Judd: That’s great news. So would you need any more money, in this line item, for this year, to complete that?

Fire Chief: Through you [i.e., through the Mayor]: I think right at this point – I mean, I’m always willing to take more money but – I think we’re OK because Durham Emergency Management has stepped up to assist us in whatever way possible to help us get to that point.

Mayor: I think if we were to offer you $5,000 and you took it then you’d be an Indian giver, so we don’t want to go there. Right?

Unidentified speaker: [inaudible]

Mayor: I know it’s politically incorrect but I couldn’t think of, in today’s generation, what they would call that. What would they call that? You have kids.

Unidentified speaker: I don’t know.

Unidentified speaker: Nothing

Mayor: Nothing? They would so. They have another phrase for it. Anyone else on this line? No? Go ahead, Rick.

Fire Chief: It’s OK. I am part Indian so – Just, I’ll move on to the stations. Nothing really jumps out –

15. The Mayor was in the chair when the exchange occurred.

16. A few days following the meeting, the Respondent placed a phone call to the Fire Chief and offered a personal apology. The Fire Chief accepted the apology.

17. Ms Miller was watching a live stream of the February 7 meeting. She did not immediately file a complaint.

18. On the evening of March 4, the Mayor and Ms Miller were both present at a meeting of the Wilfrid Hall Board of Management. Meetings are open to the public, and Ms Miller attended as she had every right to do. She was also recording the public meeting which, again, she had every right to do. A member of the public needs no particular reason to exercise the right to attend a meeting of a local board of the municipality. Nonetheless, I note that Ms Miller was formerly the Ward 4 Councillor, and during that time sat on the Wilfrid Hall Board as Council’s representative.

19. The Complainant and the Respondent disagree about what words were used, but they both agree on having different opinions about the Wilfrid Hall Board’s decision to go into closed session to consider a matter arising from my report in the case Bath-Hadden v. Pettingill, 2020 ONMIC 3. My report in that case had been considered by Council (sitting as Committee of the Whole) two days earlier.

20. The Wilfrid Hall Board considered a motion to go into closed session. Ms Miller felt the reason for the closed session should have appeared on the agenda. The Mayor disagreed. As the only member of the public present, Ms Miller left before the closed session began. The words spoken between her and the Mayor as she was leaving are a matter of disagreement between them; it is not necessary for me to resolve what actually was said.

21. The morning of March 6 (that is, about a day and a half after the Wilfrid Hall Board meeting), Ms Miller attended at the Township offices to swear an affidavit and submit the present complaint.

22. As is explained in the next section of this report, processing of this complaint was affected by the COVID-19 pandemic, and a Notice of Inquiry was not issued until June 28. At the first Council Meeting after the inquiry commenced, July 13, the Mayor addressed her February 7 use of the offensive term. She stated:⁴

I am very disappointed, though, that through social media, a video has popped up in an attempt to discredit myself I am not going to give any further play on this video. I have apologized more than once for a comment that I had made during our budget discussions and I have acknowledged it was in bad taste. At no time was there any intention on administering harm towards anyone. I am no way perfect. I regret what I said. I will continue to make mistakes, as we all will. We are only people. There is not one of us sitting here that has not made a comment that could be perceived in bad taste. From my learned mistakes, I will ask you as Council to please consider your words very carefully moving forward and learn from my error.

Process Followed

23. In operating under the Code, I follow a process that ensures fairness to both the individual bringing a complaint (Complainant) and the Council Member responding to the complaint (Respondent). This fair and balanced process includes the following elements:

• The Respondent receives notice of the complaint and is given an opportunity to respond.

• The Complainant receives the Respondent’s response and is given an opportunity to reply.

• More generally, the process is transparent in that the Respondent and Complainant get to see each other’s communications with me.

• The Respondent is made aware of the Complainant’s name. I do, however, redact personal information such as phone numbers and email addresses.

• As a further safeguard to ensure fairness, I will not help to draft a complaint and will not help to draft a response or reply.

• Where appropriate I will, however, invite a Complainant to clarify a complaint. When a complaint has been clarified the Respondent is provided with the original document and the clarification.

• When a complaint has been clarified I deem the date of final clarification to be the official date the complaint was made.

24. In this case, the complaint form was filed on March 6 and then supplemented on March 12, just prior to the declaration of the COVID-19 state of emergency.⁵

25. As Ontario was gripped by the COVID-19 pandemic and in a state of emergency, I decided to suspend further action on this file until the Province and the Township reached an appropriate state of recovery. This was not strictly permitted by Ontario Regulation 73/20, which gave power to extend deadlines and suspend proceedings to certain statutory officials, but not integrity commissioners conducting code of conduct investigations.⁶ (In fact, the Province was specifically asked to include integrity commissioner code of conduct proceedings under the Regulation, but declined to do so.) Nonetheless, given all that the residents of the Township and Ontario were experiencing, it was the right thing to do.

26. The complaint did not immediately identify the words alleged to have contravened the Code. I needed to seek clarification (pursuant to section 2.2 of the Complaint Procedure) but waited to do so until June 25, after most of the Province had entered Stage 2 of reopening.

27. I received clarification of the allegations, June 26. The date of clarification is considered to be the official complaint date.

28. In issued a Notice of Inquiry on June 28. In it, I identified as substantive issues whether the conduct reflected in the February 1 photograph contravened section 14.0 of the Code, and whether the February 7 comment contravened section 4.0 and section 14.0.

29. I also invited the parties to address two preliminary issues. First, does the Integrity Commissioner have jurisdiction to enforce section 4.0 (Council/ Committee Meeting Conduct), or is that the responsibility of the presiding officer of the meeting? Second, does the Integrity Commissioner have jurisdiction to consider a harassment complaint made by someone who is not the individual alleged to have experienced the harassment?

30. At different points, both parties asked for extensions of time to make submissions. I granted the time extensions, which had the effect of extending the inquiry beyond the 60-day target.

31. After the parties’ submissions were received, I authorized another lawyer in my office to conduct witness interviews under subsection 223.3 (3) of the Municipal Act. He interviewed the Fire Chief.

32. For reasons that I explain below, I find that it is unnecessary to interview any of the other individuals in the group photograph.

33. The February 7 comment and the July 13 apology are both matters of public record and the recordings are still online. There is no dispute about the fact of what was said.

34. The February 1 photograph is a matter of public record and, as of today, is still posted on Facebook.

35. I have carefully considered the recording of the February 7 comment, the interview of the Fire Chief, the recording of the apology, and the February 1 photo.

36. The parties have had full opportunity to address all of the allegations and issues in this proceeding. I have considered all of the information and submissions they provided.

37. I am now in a position to report to Council.

Positions of the Parties

38. In this section I am summarizing the positions of both parties. This is a summary, not the entirety, of their submissions to me. Regardless of what is summarized below, I have taken every word of their submissions into account.

Positions of parties on preliminary issue of meeting conduct

39. The Complainant takes the position that the Integrity Commissioner has jurisdiction to enforce section 4.0. She notes that it was the presiding officer who used offensive words or unparliamentary words or expressions. She relies on sections 2.0, 3.0, and 16.0 to support the position that section 4.0 is meant to be enforceable.

40. The Respondent states the Integrity Commissioner can consider any section of the Code as the Integrity Commissioner sees fit. She notes, however, that no Council Member in attendance challenged the presiding officer’s conduct, and it would be difficult for the Integrity Commissioner after the fact to rule on compliance with the Procedure By-law (which is what section 4.0 requires).

Positions of parties on preliminary issue of harassment complaint by someone who did not experience it

41. The Complainant provides several reasons to support her position that an integrity commissioner has jurisdiction to consider a harassment complaint submitted by someone other than the individual alleged to have experienced it. She points out the public interest in having elected officials act in a manner that promotes public confidence. She feels that the photo shows conduct inappropriate “in the public eye and in a public forum.” She also notes that many victims of sexual harassment do not come forward for reasons that include fear of retaliation, embarrassment, and career jeopardy.

42. The Complainant says a matter should not be overlooked simply because neither of two involved individuals files a complaint. In support of this observation, she cites the City of London case (Re Brown and Cassidy (June 21, 2016)), in which Integrity Commissioner Gregory F. Stewart took jurisdiction in response to concerns raised by Council, employees, and members of the public regarding the conduct of London’s Mayor and Deputy Mayor. She also notes that there is no restriction on who may submit a complaint, and relies on Code sections 2.0, 3.0 and 16.0.

43. The Respondent submits that only the individual alleged to have experienced harassment should be able to file a complaint. She explains: “If not, we are moving towards interpretation by any individual.”

Position of the Complainant (Therese Miller)

44. The Ms Miller alleges that the Mayor contravened section 4.0 and section 14.0 of the Code of Conduct. These provisions state, in part, as follows:

4.0 Council/Committee Meeting Conduct

Members of Council shall have regard and follow the rules of conduct contained within the municipality’s procedural by-law and specifically, members of Council shall not … Use offensive words or unparliamentary words or expressions …

14.0 Interpersonal Behaviours

Ontario Human Rights Code

Members of Council shall abide by the provisions of the Human Rights Code and, in doing so, shall treat every person, including other members of Council, corporate employees, individuals providing services on a contract for service, students on placements, and the public with dignity, understanding, and respect for the right to equality and the right to an environment that is safe and free from harassment and discrimination.

Discrimination

No member of Council shall discriminate against anyone on the basis of their race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, age, marital status, family status or disability.

Harassment & Violence in the Workplace Policy

Members of Council shall abide by the Township’s Violence and Harassment in the Workplace policies formally adopted by Council under the Occupational Health [and] Safety Act.

45. The Complainant observes that the term “Indian giver” is a racist expression that is part of a long Canadian history of racial slurs toward Indigenous Peoples. She finds the Mayor’s use of the language, “appalling, disgraceful, inappropriate and extremely hurtful.”

46. The Complainant says that the Mayor made no attempt to apologize during the February 7 meeting.

47. The Complainant says the February 1 photograph shows the Mayor engaged in “totally inappropriate” behaviour in an official capacity. She refers to the “Me Too” movement and says the conduct of elected officials is always under scrutiny.

Position of the Respondent (Mayor Bath-Hadden)

48. The Respondent acknowledges the February 7 comment and agrees it should not have been made. She says she apologized publicly, and will continue to apologize. She cannot take back the words, and so is taking ownership of her error. She is remorseful.

49. She wants her mistake to be a lesson for everyone on Council, and asks that moving forward all make a greater effort to avoid inappropriate labels.

50. The Mayor says she reached out to the Fire Chief after the meeting with a personal phone call of apology. She says (and the Fire Chief confirms) that he accepted the apology and realized that the comment was said in error.

51. In relation to the February 1 photograph, the Mayor states that she was not sitting on the Regional Chair’s lap. She says all five elected officials gathered close, to fit into the shot, and she placed her arm around the Regional Chair. She adds that if anything inappropriate occurred then an individual in the group photo, and not someone else looking at the photo, would have the right to complain.

Position of the Complainant in Reply

52. The Complainant states that the Fire Chief does not have the capacity to accept the Mayor’s apology on behalf of Indigenous Peoples.

53. The Complainant feels that the Respondent’s apology is in adequate. She notes that the apology was unspecific and never identified the offensive language used. She feels that an apology should be made in a public Council meeting, and also communicated in writing to local Indigenous communities and the local news media, and on the Mayor’s Facebook page.

54. The Complainant cites Calls to Action, the report of the Truth and Reconciliation Commission, and in particular the following recommendation:

Professional Development and Training for Public Servants

57. We call upon federal, provincial, territorial, and municipal governments to provide education to public servants on the history of Aboriginal peoples, including the history and legacy of residential schools, the United Nations Declaration on the Rights of Indigenous Peoples, Treaties and Aboriginal rights, Indigenous law, and Aboriginal–Crown relations. This will require skills-based training in intercultural competency, conflict resolution, human rights, and anti-racism.⁷

Findings of Fact

55. The facts giving rise to the complaint are not in dispute. The Respondent acknowledges using the term “Indian giver” during the Fire Department budget discussions at the February 7 Committee of the Whole meeting.

56. The Respondent’s comment was not subject to discipline or sanction by the person presiding over the meeting or by other Members of Council.

57. The Respondent subsequently apologized directly to the individual to whom her comment was directed.

58. The Respondent also publicly acknowledged during a July 13 Council meeting that her comments were unacceptable and should serve as a learning opportunity for herself, the rest of Council, and the broader community.

Issues and Analysis

59. In the Notice of Inquiry, I invited the parties to address the following issues:

Preliminary Issues

A. Does the Integrity Commissioner have jurisdiction to enforce section 4.0 (Council/ Committee Meeting Conduct), or is that the responsibility of the presiding officer of the meeting?

B. Does the Integrity Commissioner have jurisdiction to consider a harassment complaint made by someone who is not the individual alleged to have experienced the harassment?

Allegations related to February 7 language

C. Did the language contravene section 4.0 by using “offensive words”?

D. Did the language contravene section 14.0, specifically the Ontario Human Rights Code section, by failing to “treat every person, including other members of Council, corporate employees, individuals providing services on a contract for service, students on placements, and the public with dignity, understanding, and respect for the right to equality …”?

Allegation related to February 1 photograph

E. Did the conduct depicted in the photo contravened section 14.0, specifically the Harassment & Violence in the Workplace Policy section?

A. Preliminary Issue: Jurisdiction of Integrity Commissioner to enforce section 4.0 (Council/ Committee Meeting Conduct)

60. Many municipal codes of conduct have a provision similar to section 4.0, which obliges Members to observe the rules of conduct in the Township’s Procedure By-law.⁸ While the section’s underlying sentiment is understandable, the Integrity Commissioner’s role and responsibility are uncertain. The Procedure By-law and the Municipal Act give the presiding officer of a meeting the responsibility and authority to enforce the Procedure By-law. Is a provision such as section 4.0 meant to give the Integrity Commissioner jurisdiction over enforcement of a procedural by-law?

61. My view is that I do not have jurisdiction to enforce procedural by-laws, unless a Council, in the clearest of language, gives me that authority: Moore v. Maika, 2018 ONMIC 7, at paras. 64-73; Dhillon v. Moore, 2018 ONMIC 15, at paras. 73-82. Section 4.0 of the Code does not clearly state that the Integrity Commissioner is supposed to enforce the Procedure By-law and I do not interpret that it does.

62. As explained by Professor David Mullan, the first municipal integrity commissioner ever appointed in Canada, “Absent a resolution of Council requesting the Integrity Commissioner to become involved, this self-policing is part of the statutory rights and privileges of Council.”⁹

63. Under the Procedure By-law it is the Mayor’s duty to maintain order and preserve decorum during meetings of Council. Perhaps because the speaker of the comment was also presiding over the meeting, the comment was not ruled out of order at the time, or subject to any immediate objection by the chair of the meeting.

64. Given the particular disposition of this case, the issue of jurisdiction over section 4.0 is academic. In future, however, I will not entertain a complaint alleging a contravention of the Procedure By-law unless Council adopts a resolution that expressly directs me to do so.

B. Preliminary Issue: Jurisdiction of Integrity Commissioner to consider a harassment complaint made by someone who is not the individual alleged to have experienced the harassment

65. After considering the parties’ submissions on this point, I have decided to discontinue consideration of the allegation related to the February 1 photograph. I do not believe that I should consider a harassment complaint made by someone who is not the individual alleged to have experienced the harassment.

66. Harassment is a serious matter, and I accept the Complainant’s submission that sometimes a victim of harassment may be reluctant to complain. I do not, however, agree that an integrity commissioner should investigate harassment, on the basis of nothing but a group photograph, at the behest of an uninvolved person, when nobody who was present and involved saw fit to complain.

67. The Complainant says that if I interview other individuals in the group photograph then I will find that the Respondent’s physical contact (arm around shoulder) was unwelcome. I decline to do so. Everyone in the photograph is an experienced politician. Each one has the capacity to submit an integrity commissioner complaint. (I am the Integrity Commissioner also of Durham Region, and four of the five people photographed sit on Durham Regional Council.) Chasing people for their reactions would be tantamount to fishing for a complaint, something that an integrity commissioner should not do.

68. Part V.1 of the Municipal Act makes clear that the role of an integrity commissioner is request driven. This means, in the case of an alleged Code of Conduct contravention, a proper complaint. I am aware of the 2016 City of London precedent cited by the Complainant, and the approach of Integrity Commissioner Stewart is not one that I would follow. An integrity commissioner inquiry must be properly predicated.

69. A closer parallel to the approach advocated by the Complainant is City of Brampton Integrity Commissioner Report 2020-03. In that case, Integrity Commissioner Muneeza Sheikh launched what she called a “preliminary investigation” of an allegation against a councillor, following a phone call from the Mayor of Brampton, approximately four months before the alleged victim actually filed a code of conduct complaint.

70. I am not inclined to follow this 2020 Brampton precedent. First, the allegation in that case involves violent criminal conduct – distinguishable based on severity from the Beaverton Lions Club Winter Carnival group photo. Second, I do not agree with Integrity Commissioner Sheikh that the Divisional Court decision in Di Biase v. Vaughan (City), 2016 ONSC 5620, stands for the proposition that an integrity commissioner may start to investigate allegations before receiving a complaint. On the contrary, Di Biase confirms that an investigation must be predicated on a complaint.

71. Finally, I note that integrity commissioner investigations are financed entirely by municipal property taxpayers. The Province has mandated municipal integrity commissioners and codes of conduct investigations but has provided no additional funding. Further, the shutdown in response to the COVID-19 pandemic has placed great strain on municipalities and taxpayers alike. I have taken this factor into account in determining that I will not investigate an allegation of harassment based entirely on someone’s interpretation of a still photograph, when nobody present during the photo-taking alleges that anything occurred.

C. Did the Feb. 7 language contravene section 4.0 by using “offensive words”?

72. The Respondent acknowledges that she was wrong to use the offensive term. She accepts responsibility for what happened, she has apologized (and says she is willing to apologize again), and she regrets her mistake.

73. I accept the Respondent’s position that it was wrong to the use the term.

D. Did the Feb. 7 language contravene section 14.0, specifically the Ontario Human Rights Code section?

74. Section 14.0 of the Code requires Council Members, among other things, to abide by the Human Rights Code and avoid discriminatory conduct.

75. I accept the Respondent’s position that use of the offensive term was wrong and should not have occurred.

76. While the Fire Chief personally accepted the Respondent’s apology, the term is offensive to all Indigenous Peoples. The Fire Chief never claimed to speak for the Indigenous residents of the Township¹⁰ or elsewhere, nor could he.

77. In responding to the complaint, the Respondent shows awareness that it is unacceptable and hurtful to use racially insensitive language. She says she is genuinely remorseful about her error.

E. Did the conduct depicted in the Feb. 1 photo contravene section 14.0, specifically the Harassment & Violence in the Workplace Policy section?

78. For the reasons explained above, I decline to inquire further into the photograph, since nobody in the photograph complained of harassment, or of anything else.

RecommendationS

79. The Mayor and Ms Miller both agree that the February 7 remark was inappropriate.

80. I recommend that Council accept this report, which includes the finding that use of the expression “Indian giver” is inappropriate.

81. The Mayor has apologized and says she is willing to apologize again. Ms Miller argues that an apology must identify what the apology is for, and be brought to the attention of the communities affected. While I share the Complainant’s view of what an apology should contain and accomplish, the Municipal Act and the Code of Conduct give me no authority to dictate the form and content of an apology, or even to require that an apology be issued. I can only recommend.

82. I recommend that Council provide an opportunity for making and communicating a sincere apology for the use of the expression. The opportunity might include (virtual) attendance by representatives of Indigenous Peoples.

83. The Mayor advocates making this a learning experience. Ms Miller reminds us that the Truth and Reconciliation Commission of Canada called on municipal governments to deliver professional development and training to their officials. I agree with both parties.

84. I recommend that Council consider Call to Action No. 57 of the Truth and Reconciliation Commission in the context of this report, and schedule appropriate education for Council Members on the topics, including anti-racism, described in that Call to Action.

Content

85. Subsection 223.6 (2) of the Municipal Act states that I may disclose in this report such matters as in my opinion are necessary for the purposes of the report. All the content of this report is, in my opinion, necessary.

Respectfully submitted,

Guy Giorno

Integrity Commissioner

Township of Brock

October 13, 2020

Appendix

February 1 photo posted on Beaverton Lions Club Ontario Facebook page

Footnotes

1. 1Township of Brock Code of Conduct for Members of Council, By-law 2843-2019-AP.
2. 2The Club’s Facebook page is named Beaverton Lions Club Ontario, presumably to distinguish it from the page Beaverton Lions Club belonging to a group in Michigan.
3. 3The remarks start at the 4:02:35 time mark of the official recording: http://video.isilive.ca/brock/Committee%20of%20the%20Whole/Session%203%20-%20February%207,%202020.mp4.html
4. 4The remarks start at approximately the 24:03 time mark of the recording posted on the Township website.(The meeting was called to order at the 21:46 time mark.)
5. 5The provincial declaration of emergency was made at 7:30 a.m., Tuesday, March 17, 2020: O. Reg. 50/20, Order in Council 518/2020.
6. 6Ontario Regulation 73/20 was revoked September 14, 2020.
7. 7Truth and Reconciliation Commission of Canada, Calls to Action (2015), at 7.
8. 8Township of Brock Procedure By-law, By-law 2890-2019,
9. 9City of Toronto, Report on Complaint (April 6, 2005), Integrity Commissioner David Mullan, at 4.
10. 103.5 per cent of Brock’s population, according to the 2016 Census, which is based on self-identification.