The appellant, a financial investment advisor, sold real estate units to his clients and received undisclosed commissions from the developer.
He was convicted of corruptly accepting a reward under s. 426(1)(a) of the Criminal Code.
On appeal, he argued that the offence required proof of a "corrupt bargain" between the giver and the taker.
The Supreme Court of Canada dismissed the appeal, holding that the word "corruptly" in the context of secret commissions means secretly or without adequate and timely disclosure, and does not require a corrupt bargain with the giver.