Canadian Space Agency Organizational Values and Ethics Code

Values and ethics at the heart of our actions!

A message from the President

The Canadian Space Agency (CSA) is an organization that plays a singular role within the federal government owing to the unique nature of its activities. In addition, the CSA is at the forefront of the space field and carries out its mandate within a complex legal and regulatory context where it is necessary to be aware of and to comply with numerous regulations and exercise vigilance and judgment.

The Organizational Values and Ethics Code set out in the following pages is a combination of publicFootnote 1 sector values and values specific to the culture of the CSA organization.

The President and the members of the CSA Executive Committee are committed to adopting and promoting the behaviours described in this Code and to ensuring that the Code is implemented in order to provide employees with a healthy and respectful work environment. Implementation of the Code in our day to day activities will ensure the organization's credibility in the eyes of Canadians and our partners.

Acknowledgements: Thank you to the Values and Ethics Committee, the Diversified Advisory Group, the employee's group and the union members and individuals in all CSA sectors who actively participated in the consultations leading to the creation of the Organizational Values and Ethics Code.

Table of Contents

  1. Context and responsibilities
  2. The CSA Organizational Values and Ethics Code
  3. Avenues for resolution and resources

1. Context and responsibilities

1.1 A unique world

Working at the CSA makes it possible to discover a fascinating world of space science and technology. In partnership with universities, the industry, research centres and other government agencies across Canada and around the world, the CSA is helping to secure Canada's distinguished place in these priority technological development sectors. Being employed by the CSA also provides the opportunity to work with men and women who are passionate about what they do and are proud of their organization.

Established in March 1989, the CSA derives its authority from the Canadian Space Agency Act, which was assented in December 1990. CSA employees fully contribute to the Agency's mission and adapt to major issues faced by the government, the industry and the world.

It is in this unique and specific federal work environment that CSA employees carry out their duties and perform the expected activities associated with their role in the organization.

1.2 Roles and responsibilities of public servants and employeesFootnote 2

The role of federal public servants

Federal public servants have a fundamental role to play in serving Canadians, their communities and the public interest under the direction of the elected government and in accordance with the law. As professionals whose work is essential to Canada's well-being and to the enduring strength of the Canadian democracy, public servants uphold the public trust.

The Constitution of Canada and the principles of responsible government provide the foundation for the role, responsibilities and values of the federal public sector. Constitutional conventions of ministerial responsibility prescribe the appropriate relationships among ministers, parliamentarians, public servants and the public. A professional and non-partisan federal public sector is integral to our democracy.

Pursuant to the Public Servants Disclosure Protection Act (PSDPA), the CSA requires an organizational code that complements, supports and integrates the Values and Ethics Code for the Public Sector (VECPS). We employees and public servants are required to familiarize ourselves and comply with the provisions of the VECPS, the CSA Organizational Code and the Policy on Conflict of Interest and Post-EmploymentFootnote 3.

Managers – Additional expectations

Our greatest organizational challenge in meeting our values and ethics objectives is taking full ownership of the core values of the public sector and the CSA by transforming our results-driven organizational culture into a results-driven organizational culture that takes into account people and their influence on these results.

Being results-focussed while taking people into account is consistent with the public sector's management excellence objective, as defined in the Management Accountability framework (MAF), and with the characteristics of high-performance organizations.

The behaviours adopted by CSA managers and the example they set by adopting and promoting the values of the organization and the public service are of vital importance. Values and ethics are the foundation of leadership in the public service and an integral part of the key leadership competencies. To strengthen an ethical culture, managers demonstrate leadership within their team by

  • promoting dialogue and information sharing;
  • encouraging discussion and inquiry; and
  • facilitating the search for solutions and informal dispute resolution.

The President

As the deputy head of a public sector organization, the President has specific responsibilities under the PSDPA, including establishing an organization code.

The President is responsible for fostering a positive values and ethics culture. He ensures that CSA employees are aware of their obligations under the VECPS and the CSA Organizational Code. He also ensures that employees can obtain appropriate advice within their organization on ethical issues, including possible conflicts of interest.

The President ensures that the current Code, which incorporates the VECPS, and the internal disclosure process are effectively implemented in our organization and regularly assessed and followed up on.

The President also ensures the non-partisan provision of programs and services by the CSA.

The President is subject to the current Code and the Conflict of Interest Act.

1.3 Implementation of the Code and consequences of non-compliance

Because we must adhere to the VECPS and the current Organizational Code in our actions and behaviours, compliance with the VECPS, the Organizational Code and the Policy on Conflict of Interest and Post-EmploymentFootnote 4 is a condition of employment for all CSA employees and public servants, regardless of their level or position. At the CSA, we can all expect to be treated in accordance with these values. A breach of these values or expected behaviours may result in disciplinary measures, up to and including termination of employment.

2. The CSA Organizational Values and Ethics Code

The CSA Organizational Values and Ethics Code outlines in a single document both the values of the VECPS and those specific to the CSA.

The VECPS, which came into effect on April 2, 2012, outlines the expected behaviours that correspond to the values of the federal public sector:

  • Respect for democracy
  • Respect for people
  • Integrity
  • Stewardship
  • Excellence

In order to better reflect the CSA's specific environment and culture, we have added the following values to our Organizational Code:

  • Collaboration
  • Inclusiveness
  • Innovativeness
  • Well-being
  • Accountability

These values are intrinsic to the other more general values of the VECPS: collaboration is related to the principles of respect for people and excellence; inclusiveness and well-being are part of respect for people; accountability covers respect for democracy and integrity; and innovativeness pertains to excellence.

However, these values have a significant impact on the way we act in order to meet the CSA's objectives.

Public sector code values are also our values

2.1 Respect for democracy

The system of Canadian parliamentary democracy and its institutions are fundamental to serving the public interest. Public servants recognize that elected officials are accountable to Parliament and, ultimately, to the Canadian people and that a non-partisan public sector is essential to our democratic system.

Public servants shall uphold the Canadian parliamentary democracy and its institutions by

  • respecting the rule of law and carrying out their duties according to the applicable legislation, policies and directives, in a non-partisan and impartial manner;
  • loyally carrying out the lawful decisions of our leaders and supporting ministers in their accountability to Parliament and Canadians; and
  • providing decision makers with all the information, analysis and advice they need, always striving to be open, candid and impartial.

At the CSA, we ensure that the decisions of our leaders are implemented loyally. CSA employees are professional, objective and impartial, which is vital to our democratic system. In the CSA culture, democracy requires acceptance of diversity, a key CSA value.

At the CSA, respecting democracy includes

  • complying with legislation, policies and directives and acting accordingly.

Failing to respect democracy includes

  • failing to help our leaders make decisions by providing incomplete and biased advice; and
  • criticizing our employer's decisions in our public communications (e.g. social media), regardless of our political beliefs.

2.2 Respect for people

Treating all people with respect, dignity and fairness is fundamental to our relationship with the Canadian public and contributes to a safe and healthy work environment that promotes engagement, openness and transparency. The diversity of our people and the ideas they generate are the sources of our innovativeness.

Public servants shall respect human dignity and the value of every person by

  • treating every person with respect and fairness;
  • valuing diversity and the benefit of combining the unique qualities and strengths inherent in a diverse workforce;
  • helping to create and maintain a safe and healthy workplace that is free from harassment and discrimination; and
  • working with others in a spirit of openness, honesty and transparency that encourages engagement, collaboration and respectful communication.

Respect for people is a public-sector value that is reflected at the CSA in many ways. Treating people with respect, dignity and fairness is fundamental to our employees' relationships with colleagues, managers, partners, Canadians and other individuals. The CSA expects us to show civility, courtesy and decorum. The CSA does not tolerate discrimination, as defined in the Canadian Charter of Rights and Freedoms, harassment or violence between employees (regardless of their group and level) or toward third parties. In that regard, our organization has a Policy on Harassment Prevention in addition to formal and informal complaint resolution procedures.

At the CSA, showing respect for people includes

  • recognizing the value of every person;
  • demonstrating courtesy, diligence, attentiveness and professionalism;
  • using respectful language when communicating orally and in writing; and
  • fulfilling our responsibilities and obligations with respect to health and safety.

Failing to show respect for people includes

  • abusing power and using our authority or status to intimidate someone;
  • causing harm to individuals or groups by denigrating or undermining them through our words or actions; and
  • displaying or circulating suggestive material that could be interpreted as offensive to others.

2.3 Integrity

Integrity is the cornerstone of good governance and democracy. By upholding the highest ethical standards, public servants maintain and strengthen public trust in the honesty, fairness and impartiality of the federal public sector.

Public servants shall serve the public interest by

  • always demonstrating integrity and acting in a manner that will bear the closest public scrutiny, an obligation that may not be fully satisfied by simply acting within the law;
  • never using our official roles to gain advantage for ourselves or others or to place others at a disadvantage;
  • taking all possible steps to prevent and/or resolve any real, apparent or potential conflicts of interest between our official responsibilities and our private affairs in favour of the public interest; and
  • acting in such a way as to maintain our employer's trust.

At the CSA, demonstrating integrity includes

  • avoiding real, apparent or potential conflicts of interest;
  • managing files and projects with attentiveness while ensuring their integrity;
  • treating confidential information with care, so as to protect it;
  • being trustworthy; and
  • building and maintaining relationships based on integrity with colleagues (internal) and various partners (external).

Failing to demonstrate integrity includes

  • knowingly participating in unauthorizedFootnote 5 or illegal activities;
  • using CSA property or resources for personal ends;
  • claiming inappropriate, wasteful or falsified expenditures; and
  • using confidential or privileged information to gain advantage for ourselves or others.

2.4 Stewardship

Federal public servants are entrusted with the responsible use and care of public resources, for both the short term and long term.

Public servants shall use resources responsibly by

  • effectively and efficiently using the public money, property and resources they manage;
  • considering the short and long-term effects of their actions on people and the environment; and
  • acquiring, preserving and sharing knowledge and information, as appropriate.

At the CSA, providing stewardship includes

  • complying with the policies and directives on the use of public money, particularly for purchases, rentals, hospitality, travel, conferences and training;
  • behaving responsibly with respect to health and safety in our work environment and that of our colleagues;
  • participating in health and safety prevention, information and training sessions;
  • using work resources, property and time wisely, in accordance with the applicable collective agreements or the conditions of employment established by the employer;
  • respecting intellectual property, pursuant to the applicable laws, regulations and policies;
  • maintaining a secure computing environment; and
  • ensuring sound management of documents.

Failing to provide stewardship includes

  • making illegal or unacceptable use of electronic networks;
  • inappropriately using public money; and
  • mismanaging our time or the property and resources entrusted to us.

2.5 Excellence

Excellence in the design and delivery of public sector policy, programs and services is beneficial to every aspect of Canadian life. Engagement, collaboration, effective teamwork and professional development are all essential to a high-performance organization.

Public servants shall demonstrate professional excellence by

  • providing fair, timely, efficient and effective services that respect Canada's official languages;
  • continually improving the quality of policies, programs and services they provide; and
  • fostering a work environment that promotes teamwork, learning and innovativeness.

At the CSA, demonstrating excellence includes

  • performing well by demonstrating competence and professionalism;
  • having excellent job knowledge and keeping it up to date;
  • encouraging and promoting retraining, professional development and ongoing learning; and
  • maintaining a professional image and wearing appropriate attire in the workplace.

Failing to demonstrate excellence includes failing to

  • make time to acquire knowledge that could improve the quality of your work;
  • provide service in both official languages when your position requires it; and
  • follow CSA communications management protocols (media relations, spokesperson responsibilities, corporate identity management, etc.).

Values specific to the CSA

2.6 Collaboration

At the CSA, collaboration means pooling the efforts, competences and talents of various individuals in order to effectively meet our organizational objectives, both in the same work unit and across various units of the organization. This collaboration occurs in the context of respectful, positive relationships based on the interests and needs of the organization and the various internal and external partners (e.g. other departments, international space agencies, the industry, universities).

We CSA employees and public servants shall demonstrate the spirit of collaboration by

  • identifying needs and opportunities for collaboration between sectors and/or external partners in order to pool our competencies, knowledge, talents and abilities and align our actions with common CSA-specific interests while ensuring that the interests of Canadians are served;
  • recognizing that, while management is responsible for clarifying our roles and responsibilities, we are each responsible for ensuring that we fully understand our roles and responsibilities and fulfil them;
  • formally and informally recognizing the contributions of each partner;
  • openly and adequately sharing relevant information; and
  • treating others with fairness and dignity even in their absence.

Failing to demonstrate collaboration includes

  • knowingly keeping to ourselves relevant information that could help our colleagues, managers and partners do their work more effectively and meet their organizational objectives; and
  • using denigrating and disrespectful language towards our partners, whether present or absent, in meetings or any other work context.

2.7 Inclusiveness

Demonstrating inclusiveness means adhering to diversity values and applying the principles of non-discrimination and employment equity. In other words, it means attaching value to people's various talents and viewpoints, regardless of their age, gender, ethnic origin or reporting level, and recognizing that inclusiveness is essential to achieving our objectives with excellence; seeking and highlighting each person's contributions and input; creating a work environment that encourages all persons to participate and do their part while respecting ideas and opinions that differ from their own; and recognizing differences and striving to reach a consensus when making decisions while respecting each person's roles and responsibilities and abiding by decisions made by authority figures.

We CSA employees and public servants shall demonstrate inclusiveness by

  • soliciting the viewpoints of various individuals and groups, and expressing our point of view;
  • respecting and being open to viewpoints, ideas and opinions that may differ from our own;
  • eliminating all stereotypes relating to gender, race or ethnic origin in verbal, written and electronic communications; and
  • establishing and maintaining a work environment free of discrimination, harassment and violence.

Failing to demonstrate inclusiveness includes

  • talking about people rather than ideas and spreading gossip; and
  • passing judgment on the quality of the work produced by our colleagues, managers and partners on the basis of their age, level of education, position level, ethnic origin, etc.

2.8 Innovativeness

Like collaboration, innovativeness is a key component of the CSA's mission. With regard to the CSA's mission, the objective of innovativeness is to be at the forefront of the development and application of space knowledge for the benefit of Canadians. Innovativeness is the ability to use our knowledge, understanding, creativity, flexibility and critical thinking to develop new applications, procedures, processes and technology in all the spheres of activity that help the CSA fulfil its mandate.

We CSA employees and public servants shall seek to identify new and better ways to achieve our objectives by

  • fostering an open environment while encouraging our colleagues and partners to share new ideas, which are evaluated objectively, based on their applicability and effectiveness in relation to the CSA's mandate;
  • keeping abreast of new technological, scientific, administrative or management knowledge and trends in order to optimize our work methods and results in our ongoing activities;
  • promoting creative thinking while emphasizing innovativeness and expected outcomes; and
  • monitoring, identifying and presenting to management the latest advances in order to optimize and develop new work methods, contributing to the decision-making process.

Failing to be innovative includes

  • doing our work without listening to new ideas presented by our peers, employees and/or partners, which could allow us to do things in a better, more effective way; and
  • not seeking to increase our knowledge of new trends, tools and methods in the context of our activities.

2.9 Well-being

Well-being in the workplace is fundamental to high-performance organizations because its employees' input is essential to fulfilling its mission. Promoting and adopting all the other values of the public sector and the CSA are the key to achieving well-being at work, on both an individual and organizational level. Well-being is therefore a responsibility shared by the individual and the organization, and is a prerequisite for high-performance organizations.

We CSA employees and public servants shall commit to promoting well-being in the workplace through all our actions and behaviours at work by

  • exercising diligence and judgment in potential conflicts of interest;
  • displaying the expected behaviours for each value in the Code; fostering and maintaining well-being in the workplace by respecting the letter and spirit of the Code;
  • ensuring that we manage our time effectively to maintain balance and promote well-being;
  • seeking to achieve work-life balance (managers must be open, sensitive and receptive while referring to the collective agreements, policies and regulations in effect);
  • encouraging thoughtful, useful acts that contribute to work performance and the work environment; and
  • helping to create and maintain a healthy, welcoming, respectful and trusting work environment.

Failing to promote well-being includes

  • acting in contravention of the letter and spirit of the Code.

2.10 Accountability

CSA employees must be able to account for their actions and decisions while carrying out their duties in accordance with the applicable laws, policies, directives and codes.

We CSA employees and public servants shall demonstrate accountability by

  • making decisions with the interests of the organization in mind, preferably while striving to reach a consensus and providing strategic direction (leaders);
  • respecting decisions made by authority figures and helping to ensure that they come to fruition;
  • demonstrating thoroughness, independence and diligence, and working constructively to meet the organization's objectives;
  • ensuring that we are able to account for our actions and decisions, based on the values of the Code;
  • helping to enhance the CSA's image and reputation: we are subject to the duty of loyalty and must exercise caution and restraint to ensure that we do not threaten the impartiality, integrity or neutrality of the public service while carrying out our duties;
  • taking responsibility for our decisions, words and actions;
  • being impartial and fair when choosing scientific and technical projects that align with our mandate and mission, and being fully aware of the need to manage these projects responsibly;
  • avoiding any type of real or apparent conflict of interest between employees who have contractual, scientific or technical authority at the CSA and external partners/suppliers; and
  • adopting behaviour that protects our environment for current and future generations, which means minimizing our consumption of energy, office supplies (especially paper), cleaning products and potable water at work and when travelling, and disposing of waste and electronic waste in a responsible manner.

Failing to demonstrate accountability includes

  • refusing to take responsibility for our words and actions; and
  • refusing to respect the decisions made by authority figures.

3. Avenues for resolution and resources

Fulfilling and conforming to the expectations set out in the CSA Organizational Values and Ethics Code is, first and foremost, an individual responsibility that belongs to each employee.

If, while carrying out our duties or conducting external activities, we are unsure as to whether our behaviour complies with the Code, we must exercise vigilance and judgment while ensuring that we adhere to the Code.

We can discuss, and alleviate, our concerns with our immediate supervisor or manager. We can also consult the resources listed in the reference section below, as needed.

In terms of values and ethics, dilemmas, doubts and value conflicts are inevitable. Open dialogue is encouraged to ensure that we uphold the values, and display the associated expected behaviours, set out in the Code. CSA employees at all levels are expected to resolve conflicts in a fair and respectful manner and consider informal processes, such as dialogue or mediation.

The Code was designed to guide our actions as CSA employees and public servants. However, it cannot possibly cover all the situations which may arise in the performance of our duties.

In cases not covered by the Code, we must determine the appropriate action to take by exercising judgment and basing our decisions on the values of the public sector and the organization.

The following questions may help you make good decisions and act in accordance with expectations:

  • Are my actions legal and do they comply with CSA and Treasury Board Secretariat policies?
  • Are my actions consistent with the values of the CSA and the public sector?
  • What are the consequences of the action I am about to take or the decision I am about to make?
  • How might the media or the general public perceive this measure or decision?

Remember that

  • if you think or realize that your behaviour might go against the Code, it is most likely inappropriate, and you are better off changing your behaviour. When in doubt, ask questions and make sure they are answered.

The following is an exhaustive list of available resources:

Senior Officer Responsible for Disclosure of Wrongdoing

The Senior Officer Responsible for Disclosure of Wrongdoing is responsible for receiving information on acts allegedly committed at work, conducting investigations and making recommendations for action to our President.

Departmental Officer for Conflict of Interest and Post-employment Measures

The Departmental Officer for Conflict of Interest and Post-employment Measures is responsible for providing advice on and implementing conflict of interest and post-employment measures.

Senior Officer Responsible for Values and Ethics

The Senior Officer responsible for Values and Ethics is responsible for interpreting the CSA's Organizational Values and Ethics Code.

Departmental Coordinator for the Prevention and Resolution of Harassment in the Workplace

The Departmental Coordinator for the Prevention and Resolution of Harassment in the Workplace is responsible for harassment prevention and resolution initiatives at the CSA and coordinating the complaint process.

CSA Designated Political Activities Representative

The Designated Political Activities Representative is responsible for providing advice and guidance on political activities and acting as a liaison between the CSA and the Public Service Commission (PSC) responsible for administering the political activities regime.

CSA Values and Ethics Committee

This committee is responsible for coordinating, planning, developing, implementing, communicating and monitoring values and ethics activities, policies and guidelines at the CSA in order to provide a forum for ethical issues. The Committee also helps to achieve results, ensures that values and ethics are an integral part of our decision-making process and prepares reports and action plans relating to values and ethics activities for the CSA's Executive Committee.

In addition to the various departmental officers and senior officials who have specific responsibilities pertaining to values and ethics, the Committee is composed of representatives from each of the CSA branches, who employees can approach with values and ethics questions, comments or suggestions they would like to see addressed.

Health And Safety

Through the values of respect for people, well-being, stewardship and accountability, the Code outlines our responsibilities and obligations with regard to health and safety.

The CSA's equipment, facilities and services pose potential risks to the health and safety of the organization's employees.

That is why we must all behave responsibly with respect to our health and safety and that of our coworkers.

To do so, we must

  • apply the work methods and safety rules specific to our work area;
  • display appropriate behaviour in order to protect our health and safety and that of our work colleagues;
  • actively participate in health and safety prevention, information and training sessions; and
  • report any situation that could pose a risk to our health and safety and that of our work colleagues.

In doing so, we respect ourselves and others. for more information, you can also consult Part II of the Canada Labour Code.

CSA Policy Health and Safety Committee

This committee is responsible for examining health and safety issues at the CSA.

CSA workplace health and safety committees

Employer and employee representatives on these committees are responsible for working together to prevent work-related accidents and illnesses.

CSA National Union-Management Consultation Committee (NUMCC)

The purpose of this committee is to allow the employer and bargaining agents to discuss information and obtain feedback and advice on workplace issues. The issues discussed by the committee members pertain to the entire CSA.

St-Hubert Regional Labour-Management Consultation Committee (SHRLMCC) and Ottawa Regional Labour-Management Consultation Committee (ORLMCC)

These are standing committees of the CSA NUMCC. The issues discussed by the committee members pertain to the region represented by the committee. The committees are composed of employer and employee representatives from those regions.

CSA Employment Equity Advisory Committee

This committee is responsible for facilitating the creation of a work environment conducive to diversity management.

CSA Women in Science, Technology and Management Committee

This committee is responsible for embracing and promoting inclusiveness. Its mission is to promote a work ethic and best practices that ensure optimal performance for women in the workplace and help achieve better representation of women in management and executive positions.


Available or upcoming values and ethics courses, workshops are designed to ensure a common understanding of the values of the public sector and the CSA and facilitate their application.

Appendix I

Policy on Conflict of Interest and Post-Employment

Public servants contribute in a fundamental way to good government, democracy and Canadian society through the loyal, impartial and non-partisan support they provide to the elected government and through the service they provide to Canadians. As specialized professionals, they serve the public interest and uphold the public trust.

The Policy on Conflict of Interest and Post-Employment elaborates on the VECPS and is aligned with its content. It provides direction and measures to help organizations and public servants effectively deal with real, potential and apparent conflicts of interest, which may arise during and after employment in the public service. Preventing, managing or resolving conflicts of interest is one of the principal means of maintaining public trust and confidence in the impartiality and integrity of the public service.

Do you have a conflict of interest?

A conflict of interest exists when we are placed in a situation where we risk furthering our own interests before those of the public or the CSA.

We must therefore avoid putting ourselves in any real, potential or apparent conflicts of interest. We are responsible for meeting the requirements of the Policy on Conflict of Interest and Post-Employment both at work and outside work.

The following should be taken into consideration:

  • external activities and employment;
  • reportable assets;
  • participation on the board of directors of organizations that deal with the CSA;
  • participation in networking activities;
  • participation in political activities;
  • gifts, hospitality or other benefits;
  • preferential treatment;
  • staffing or financial decisions;
  • activities or employment engaged in after leaving the public service.

When is there an apparent conflict of interest?

A conflict of interest exists when a situation might be perceived as a conflict of interest, even though there is no real conflict of interest.

Therefore, when a relatively well informed person could conclude that we are carrying out our duties on the basis of our personal interests or the interest of our friends and family, there is an apparent conflict of interest. Managers must disallow any action that could be perceived as an apparent conflict of interest. Employees must inform their supervisor, through a confidential report, of any role, activity or duty they are carrying out outside the CSA and of any assets or interests that are likely to influence or could be perceived as influencing their decisions in the performance of their duties.

We must also be objective and impartial when making decisions involving staffing, contract award or project operations.

Each individual is responsible for taking the measures required to recognize, prevent, report or resolve any real, apparent or potential conflicts of interest between our official and personal responsibilities.


Footnote 1

Reference :

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Footnote 2

Most CSA employees are public servants hired under the Public Service Employment Act. However, the CSA can hire astronauts who are CSA employees but not public servants. Astronauts are subject to the CSA Organizational Code.

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Footnote 3

See Section 1.3, Implementation of the Code and consequences of non-compliance.

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Footnote 4

Also see Appendix I

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Footnote 5

For example, taking part in unauthorized political activities or speaking at a conference as a CSA representative without permission.

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