• What is a Code of Conduct?

  A code of conduct is a written document that sets shared expectations for conduct or behaviour. A local government council or board can adopt a code of conduct to establish shared expectations for how members should conduct themselves while carrying out their responsibilities and in their work as a collective decision-making body.

  Responsible conduct of elected officials is not optional; it is essential to good governance. Responsible conduct refers to how government elected officials conduct themselves with their elected colleagues, with staff, and with the public. It is grounded in conducting oneself according to principles such as integrity, accountability, respect, and leadership and collaboration.

  A code of conduct is one tool that can be used by a local government council or board to promote or further responsible conduct.

  Source: MODEL CODE OF CONDUCT: GETTING STARTED ON A CODE OF CONDUCT FOR YOUR COUNCIL/BOARD, Produced by the Working Group on Responsible Conduct; a joint initiative of the Union of BC Municipalities (UBCM), The Ministry of Housing and Municipal Affairs, and the Local Government Management Association (LGMA).

• How are Code of Conduct Investigators Selected?

  Pursuant to the terms of the Council Code of Conduct Bylaw, when a Code of Conduct complaint is submitted, the City’s Chief Administrative Officer (or the Corporate Officer if the complaint involves the Chief Administrative Officer) must retain an Investigator.  The Chief Administrative Officer (or Corporate Officer, as the case may be) is required by the Code of Conduct to retain a qualified, independent, and objective third party to act as Investigator and assist in resolving the complaint. In most instances, they seek legal advice to assist with the retainer.

  Typically, the Investigator must:

  • be a lawyer in good standing with the Law Society of British Columbia;
  • have experience working with municipal corporations and elected officials;
  • have experience conducting municipal code of conduct investigations and drafting municipal code of conduct investigation reports; and
  • have experience interpreting municipal codes of conduct, other statutes, and court decisions which govern municipal governments.

  
  It is common for a municipality to use the same Investigator for many or even all its code of conduct complaints – the Investigator becomes familiar with the municipality’s specific code of conduct and is therefore able to conduct investigations more efficiently than a new investigator interpreting the code of conduct for the first time. By using the same Investigator for its Code of Conduct complaints, the City of Kamloops also ensures consistency between complaints (e.g., consistent investigation procedures, Code of Conduct interpretation, report content etc.).

  To date, the City has engaged two Code of Conduct investigators, as noted below.

Code of Conduct Breaches Substantiated

• Complaint #2023-0001

  Date	July 2023
  Subject of Complaint	Councillor Neustaeter alleged Mayor Hamer-Jackson breached the Code of Conduct Bylaw by misleading the public.
  Bylaw Sections Engaged	3.11(a)
  Investigator	Sarah Chamberlain of Southern Butler Price LLP
  Investigation Fees	$8,904 (includes complaint #2023-0002)

  Conclusion

  • The Investigator found that the Mayor's evidence was inconsistent and not credible. 
  • The Investigator found that the Mayor was in breach of his obligations under s. 3.11(a) by making public statements he knew or ought to have known were false or misleading. 
  • The Investigator found that "There is no evidence to corroborate his statements...are true and not misleading."
  • This was investigated at the same time as Complaint #2023-0002, and therefore reported together in the below investigation and addendum reports. 

  Investigation Report Addendum Report

  Council Resolutions

  At the February 6, 2024, closed Council meeting, pursuant to section 4.35 of the Code of Conduct Bylaw, Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breach are as follows:

  1. A request that Mayor Hamer-Jackson issue a letter of apology, in a form and with content acceptable to Council, within 30 days of receiving the draft letter.
  2. Mayor Hamer-Jackson must complete mandatory training on his obligations under the Code of Conduct, which training must be completed by June 30, 2024.
  3. Mayor Hamer-Jackson must complete mandatory training on respectful workplace communications and other interpersonal skills, which training must be completed by June 30, 2024.

  
  On March 5, 2024, Mayor Hamer-Jackson was provided with the letter of apology in a form and with content that was acceptable to Council. Therefore, the deadline for signing and delivering the letter of apology was June 5, 2024.

  Mayor Hamer-Jackson refused or neglected to sign and deliver the letter of apology by June 5, 2024. Reminders were sent to him.

  At the June 11, 2024, closed Council meeting, pursuant to section 4.38 of the Code of Conduct Bylaw [additional measures due to non-compliance], Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breach and by Mayor Hamer-Jackson’s failure to comply with Council’s December 10, 2024, resolution were as follows:

  1. Effective immediately, the remuneration to which he would otherwise be entitled will be reduced by ten (10%) percent until the earlier of: (a) six (6) months; or until he has signed and delivered the apology letter.

  
  By December 10, 2024, Mayor Hamer-Jackson had refused or neglected to sign and deliver the apology letter in accordance with Council’s February 6, 2024, and June 11, 2024, resolutions.

  At the December 10, 2024, closed Council meeting, pursuant to section 4.38 of the Code of Conduct Bylaw [additional measures due to non-compliance], Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breach and Mayor Hamer-Jackson’s failure to comply with Council’s February 6, 2024, and June 11, 2024, resolutions are as follows:

  1. Effective December 12, 2024, unless the Mayor has signed and delivered the apology letter to Councillor Neustaeter, the remuneration to which he would otherwise be entitled will be reduced by fifteen (15%) percent; and
  2. This reduction in remuneration will remain in effect until such time as Mayor Hamer-Jackson has signed and delivered the apology letter to Councillor Neustaeter.
• Complaint #2023-0005

  Date	August 2023
  Subject of Complaint	The Complainant (member of the public) alleged Councillor Sarai was disrespectful to, bullied and harassed, and made false accusations of another member of Council about a matter in which he had a conflict of interest.
  Bylaw Sections Engaged	3.1, 3.2, 3.3, 3.8, 3.11, 3.14, and 3.18
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$66,411.46 (includes complaints #2023-0003, 2023-0004, 2023-0005, and 2023-0006)

  Conclusion

  • Majority of Complaint summarily dismissed. 
  • One component of Complaint proceeded to investigation. The Investigator concluded there was a trivial breach.
  • The Investigator determined that, while there was a breach of the Code of Conduct, it was of a trivial nature and done because of an error in judgment made in good faith, as per subsection 4.32(c) of the Code of Conduct Bylaw. In fact, the Investigator noted that "perhaps some consideration should have been given by the complainant as to the purpose of filing it in the first place". 
  • Accordingly the Investigator strongly recommended that no censure, sanctions, corrective actions, or other measures be imposed. Council accepted the Investigator's recommendation.

  Investigation Report

• Complaint #2024-0019

  Date	March 2024
  Subject of Complaint	Councillor Bass alleged Mayor Hamer-Jackson breached the Code of Conduct and FIPPA.
  Bylaw Sections Engaged	3.1, 3.2, 3.3, 3.11, and 3.15
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$60,957.16

  Conclusion

  • The Investigator found that Mayor Hamer-Jackson breached section 3.15(a) of the Code of Conduct and section 25.1 of the Freedom of Information and Protection of Privacy Act when he forwarded photographs of individuals in downtown Kamloops to the Chamber of Commerce Executive Director.
  • The Investigator stated that he could not find that Mayor Hamer-Jackson took reasonable steps to prevent the breach, that the breach was trivial or inadvertent, or that the breach occurred because of an error in judgment made in good faith. The Mayor was given many opportunities to participate in the investigation and refused to do so. As such, the Investigator concluded that Mayor Hamer-Jackson took no steps to avoid this breach.
  • The Investigator found that there was a clear act by Mayor Hamer-Jackson that he should have known would constitute a breach of the Code of Conduct. He requested and received photographs from the third party. At that point, he either reviewed the photographs and forwarded them to the Chamber of Commerce Executive Director, or he did not review them and forwarded them despite not knowing their contents. For the purposes of FIPPA, whether the Mayor knew what the photographs depicted or not is irrelevant - he collected and disclosed records that contained personal information. This reflects one of the many principles that FIPPA is intended to reflect. Local governments and their elected officials are required to adhere to certain standards when they collect, use, or disclose personal information. The Investigator stated that "the Mayor has fallen well below those standards in these circumstances."
  • The Investigator found that whether or not he was aware that his actions would breach FIPPA, Mayor Hamer-Jackson ought to have known that the photographs contained personal information and that, as such, he should not have collected them from and transmitted them to persons who are external to the City.
  • The Investigator noted that: "In the course of our investigation, it came to our attention that the Mayor’s decision to forward the Photographs to the CoC Executive Director may have engaged the Intimate Images Protection Act (the “IIPA”), in addition to FIPPA. However, at that time I determined not to include the IIPA in our investigation. I made this determination largely because the IIPA was not cited in the complaint – or in any of our subsequent correspondence with the Complainant – and is not directly referenced in the relevant Code of Conduct provisions. As a result, our processing of the complaint until that time, which included multiple notifications to the Mayor and his legal counsel, did not include any notice or assessment of whether the IIPA was breached. Given all of these factors, and a procedural fairness concern of late notice, I choose not to include the IIPA in this investigation."

  Investigation Report

  Council Resolutions

  At the December 10, 2024, closed Council meeting, pursuant to section 4.35 of the Code of Conduct Bylaw, Council directed that the appropriate censures, sanctions, corrective actions, and other measures warranted by the Breach are as follows:

  1. Within 30 days of receiving notice of this resolution, Mayor Hamer-Jackson must provide a letter of apology to both the KCBIA Executive Director and the Chamber of Commerce Executive Director in a form and with content acceptable to Council, to be drafted by the Deputy Mayor in consultation with legal counsel;
  2. The Mayor will be publicly censured by Council resolution in an open meeting, the contents of which will be drafted by Councillor Hall for Council’s approval;
     Public Censure
  3. Within sixty days (60) days of receiving notice of this resolution, Mayor Hamer-Jackson must take personalized mandatory training on his obligations regarding personal information under FIPPA, which said training must be A) in a form and with content acceptable to Council; and B) delivered by a qualified professional acceptable to Council;
  4. Should the Mayor refuse or fail to:
     
     1. deliver the letters of apology to both the KCBIA Executive Director and the Chamber of Commerce Executive Director as specified above; or
     2. participate in and complete mandatory training specified above, the remuneration to which the Mayor would otherwise be entitled shall be reduced by ten (10%) percent, for a period of twelve (12) months.

  
  On December 16, 2024, Mayor Hamer-Jackson was provided with notice of Council’s December 10, 2024, resolution together with draft versions of the letters of apology in a form and with content acceptable to Council.

  By January 17, 2025, Mayor Hamer-Jackson had refused or neglected to sign and deliver the letters of apology as directed by Council in its December 10, 2024, resolution and as a result, the remuneration to which Mayor Hamer-Jackson would otherwise be entitled was reduced by 10% for a period of twelve (12) months.

  By April 8, 2025, Mayor Hamer-Jackson had also refused or neglected to comply with Council’s resolution by undertaking personalized mandatory training on his obligations regarding personal information under FIPPA as directed by Council in its December 10, 2024, resolution.

  At the April 8, 2025, closed Council meeting, pursuant to section 4.38 of the Code of Conduct Bylaw [additional measures due to non-compliance], Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breach and Mayor Hamer-Jackson’s ongoing failure to comply with Council’s December 10, 2024, resolution are as follows:

  1. Effective immediately, the remuneration to which Mayor Hamer-Jackson would otherwise be entitled shall be reduced by an additional ten (10%) percent until such time as the Mayor has satisfied Council that he has undertaken personalized mandatory training on his statutory obligations under the Freedom of Information and Protection of Privacy Act regarding personal information and his governance obligations under the Community Charter, all of which said training must be:
     
     1. in a form and with content acceptable to Council; and
     2. delivered by a qualified professional acceptable to Council.
• Complaint #2024-0020

  Date	April 2024
  Subject of Complaint	Councillor Bass alleged Mayor Hamer-Jackson repeatedly breached confidentiality and privacy by releasing a privileged and confidential report and closed council meeting resolution to the media.
  Bylaw Sections Engaged	3.1, 3.2, 3.3, 3.8, 3.10, 3.11, 3.15, 3.18, and 3.22
  Investigator	Reece Harding of Young Anderson
  Investigation Costs	$46,413.26

  Conclusion

  • The Investigator found that Mayor Hamer-Jackson breached sections 3.15(a) of the Code of Conduct and 117(1)(a) of the Community Charter when he released a privileged and confidential report to the media in early April 2024. 
  • The Investigator also found that Mayor Hamer-Jackson breached sections 3.15(a) of the Code of Conduct and 117(1)(a) of the Community Charter when he released a resolution from a closed council meeting.
  • The Investigator stated that Mayor Hamer-Jackson's behaviour in releasing the report and the resolution was "a substantial departure from the standard to be expected of a mayor" and that "Mayor Hamer-Jackson has shown no willingness to take any responsibility for his actions, and Council must proceed on the assumption that he is likely to continue to disclose confidential documents either through lack of care or simply when it suits him".

  Investigation Report

  Council Resolutions

  At the September 24, 2024, closed meeting, pursuant to section 4.35 of the Code of Conduct Bylaw, Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breaches are as follows:

  1. a letter of reprimand from Council addressed to Mayor Hamer-Jackson;
  2. a request from Council that Mayor Hamer-Jackson issue a letter of apology, in a form and with content acceptable to Council;
  3. a public censure of Mayor Hamer-Jackson by Council;
     Public Censure
  4. a direction that Administration, in consultation with legal counsel and the Deputy Mayor of the day, place limits on Mayor Hamer-Jackson’s access to confidential information necessary to protect the corporation on a case-by-case basis; and
  5. a direction that the remuneration to which Mayor Hamer-Jackson would otherwise be entitled be reduced by 15% for a period of 12 months.

  
  On November 1, 2024, a physical copy of the draft apology letter as well as an electronic copy of the draft apology letter was delivered to Mayor Hamer-Jackson for his signature and return to Council, pursuant to Council’s September 24, 2024, resolution;

  By February 25, 2025, Mayor Hamer-Jackson had refused or neglected to sign and deliver a copy of the apology letter as directed by Council’s September 24, 2024, resolution.

  At the February 25, 2025, closed Council meeting, pursuant to section 4.38 of the Code of Conduct Bylaw [additional measures due to non-compliance], Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breaches and Mayor Hamer-Jackson’s ongoing failure to comply with Council’s September 24, 2024, resolution are as follows:

  1. By 2:00 PM on Wednesday, March 5, 2025, Mayor Hamer-Jackson must sign and deliver to Deputy Mayor Bepple the letter of apology in the form previously provided on November 1, 2024, failing which, the vehicle allowance to which Mayor Hamer-Jackson would otherwise be entitled will be revoked, effective March 6, 2025, until such time as Mayor Hamer-Jackson has complied with Council’s September 24, 2024 direction; and
  2. Council directs Administration, in consultation with legal counsel and the Deputy Mayor of the day, to place additional limits on Mayor Hamer-Jackson’s access to confidential information necessary to protect the corporation on a case-by-case basis.
• Complaint #2024-0023

  Date	December 2024
  Subject of Complaint	Councillor Hall alleged Councillor Sarai breached the Code of Conduct by recording a conversation between himself and Mayor Hamer-Jackson without the Mayor’s knowledge and later publicly denying any knowledge of the source of the recording.
  Bylaw Sections Engaged	3.2 and 3.3(a)
  Investigator	Reece Harding of Young Anderson
  Investigation Fees to Date	$39,544.56

  Conclusion

  • The Investigator found that Councillor Sarai’s conduct constituted a breach of sections 3.2 and 3.3(a) of the Code of Conduct.
  • In reaching this finding, the Investigator found the following facts to be of particular significance:
    • Councillor Sarai anticipated that his conversation with the Mayor on January 20, 2023 would be contentious, and recorded their conversation without informing the Mayor;
    • Councillor Sarai decided to create the recording rather than speak with the Mayor with another Council member present;
    • Councillor Sarai kept the recording, even after the adoption of a Council Policy prohibiting such recordings on November 21, 2023;
    • Councillor Sarai sent the recording to the Mayor so that he would “think twice about lying”;
    • When Councillor Sarai sent the recording to the Mayor, he implied that it was sent to him by someone else;
    • On October 16, 2024, in response to reports that the Mayor was concerned his office was bugged as a result of Councillor Sarai sharing the recording, Councillor Sarai publicly denied having any knowledge of the source of the recording and described the Mayor as “paranoid and delusional”.
  • The Investigator found that these facts illustrated a pattern of misdirection that falls short of Councillor Sarai’s obligation to carry out his duties with integrity, to respect others, and to demonstrate leadership and collaboration.
  • The Investigator noted that Councillor Sarai may have had legitimate concerns and grievances when he created the recording and decided to use it to try to persuade the Mayor to “tell the truth” about the conversation they had on January 20, 2023. However, the manner in which Councillor Sarai conducted himself falls short of the standards that are set out in the Code of Conduct and breaches the oath of office that he swore when he was elected.

  Investigation Report

  Council Resolutions

  On May 27, 2025, pursuant to section 4.35 of the Code of Conduct Bylaw, Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breach are as follows:

  1. A letter of reprimand from Council;
  2. Councillor Sarai will sign and deliver a letter of apology to Mayor Hamer-Jackson and a letter of apology to Council, staff, and the public within thirty (30) days of receiving the approved forms from the Deputy Mayor;
  3. Councillor Sarai will take mandatory training on respectful workplace communications or other interpersonal skills within sixty (60) days of receiving notice of the resolution.
  4. In the event Councillor Sarai fails to comply with either of the requirements in (b) and (c) above within the stipulated timelines, the remuneration to which he would otherwise be entitled will be reduced by five percent (5%) for a period of six (6) months or until he fully complies with both requirements, whichever is earlier.

  Compliance

  At its July 29, 2025, closed meeting, Council received an update from Councillor Sarai, wherein Councillor Sarai confirmed he has now fully complied with the sanctions imposed by Council on May 27, 2025. In particular, Councillor Sarai confirmed he has:

  • signed and delivered the letter of apology to Mayor Hamer-Jackson;
  • signed and delivered the letter of apology Council, staff, and the public; and
  • taken mandatory training on respectful workplace communications and other interpersonal skills. 

  Councillor Sarai completed the above requirements prior to the expiry of their respective deadlines. As a result, there will be no suspension of his remuneration. 

  Letter of Reprimand
   

• Complaint #2025-0024

  Date	January 2025
  Subject of Complaint	Councillor Bass alleged that Mayor Hamer-Jackson contravened the conflict of interest rules contained in the Community Charter when he participated in and voted on a matter involving a member of the public whom he is suing.
  Bylaw Sections Engaged*	3.1, 3.8, 3.11, and 3.18
  Investigator	Reece Harding of Young Anderson
  Investigation Fees to Date	$29,863.65

  *Investigator retains discretion to determine applicable sections of Code of Conduct Bylaw.
   

  • The Investigator found that Mayor Hamer-Jackson breached sections 3.18 and 3.19 of the Code of Conduct when he voted on a temporary use permit application that was before Council while under a conflict of interest (the “Breach”). The breach arose from the fact that Mayor Hamer-Jackson was, at the time he cast his vote, maintaining a defamation lawsuit against the principal of the applicant corporation and in a conflict of interest as a result.
  • The Investigator concluded:
    • “In my view, it is clear that Mayor Hamer-Jackson had a personal interest in Council’s consideration of the TUP application, due to his ongoing lawsuit against the applicant’s principal, Joshua Knaak. That litigation created a link between a personal consideration – the lawsuit – and the Mayor’s public law duty to vote on land use applications in a manner that reflects the public interest. I consider the Mayor’s interest a highly personal one, which is clearly distinct from the rest of the Council and certainly distinct from the electorate as a whole.”
    • “I have already noted the nature of the lawsuit, which is of a serious character. Whether or not the Mayor believed that it was filed for a defensive purpose is irrelevant. The accusations the Mayor makes in the lawsuit regarding Mr. Knaak’s statements are sufficient to create a public perception of a lack of impartiality as regards the Mayor’s exercise of public powers in relation to the principal of the applicant, Mr. Knaak.”
    • “I find, therefore, that the Mayor breached sections 3.18 and 3.19 of the Code by casting his vote on the TUP application at issue on November 26, 2024. The Mayor, in my view, had a non-pecuniary conflict of interest as defined by both the Code and the Community Charter.”

  Investigation Report

  Council Resolutions

  At the July 29, 2025, closed meeting, pursuant to section 4.35 of the Code of Conduct bylaw, Council directed that the appropriate censures, sanctions, corrective actions, and/or other measures warranted by the Breach are as follows:

  1. Within 7 business days from the date on which the City delivers notice of Council’s July 29, 2025 resolution to him, Mayor Hamer-Jackson must provide to Council a general description of the legal advice he claims to have had on November 26, 2024, together with some objective form of proof, such as confirmation from a lawyer duly qualified to practice law in British Columbia.
     
     1. If Mayor Hamer-Jackson fails to provide the objective proof required in paragraph (1) within the stipulated timeline, the remuneration to which he would otherwise be entitled will be automatically reduced by ten percent (10%) until such time as he complies with the requirement.
  2. Mayor Hamer-Jackson must sign and deliver a letter of apology to Joshua Knaak, in a form and with content approved by Council, within thirty (30) calendar days from the date on which the draft letter of apology is delivered to Mayor Hamer-Jackson. 
     
     1. If Mayor Hamer-Jackson fails to sign and deliver the letter of apology required in paragraph (2) within the stipulated timeline, the remuneration to which he would otherwise be entitled will be automatically reduced by a further ten percent (10%) until such time as he complies with the requirement.
  3. Within sixty (60) calendar days from the date on which the City delivers notice of Council’s July 29, 2025 resolution to him, Mayor Hamer-Jackson must take mandatory training on his obligations under the Community Charter and the Local Government Act, including with respect to conflicts of interest and his oath of office.
     
     1. If Mayor Hamer-Jackson fails to take the mandatory training required in paragraph (3) within the stipulated timeline, the remuneration to which he would otherwise be entitled will be automatically reduced by a further ten percent (10%) until such time as he complies with the requirement.
  4. A public censure of Mayor Hamer-Jackson by Council will be published on the Council Leadership and Accountability page of the City’s website, along with all other outstanding censures of Mayor Hamer-Jackson by Council that have not yet been published.

  Mayor Hamer-Jackson was provided with Notice of Council's July 29, 2025, decision on August 1, 2025.

Investigations In Progress

• Complaint #2025-0025

  Date	April 2025
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent made public statements which the Respondent knew or ought to have known were false or misleading.
  Bylaw Sections Engaged*	3.1, 3.2, 3.8, and 3.11
  Investigation Fees to Date	$29,320.52

  *Investigator retains discretion to determine applicable sections of Code of Conduct Bylaw.

• Complaint #2025-0029

  Date	June 2025
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent breached their privacy obligations by improperly disclosing third party personal information in their email correspondence. The Complainant further alleged that the Respondent harassed, intimidated, and obstructed City staff in the course of their statutory duties.
  Bylaw Sections Engaged*	3.1, 3.8, 3.11, 3.15, 3.22, and 3.23
  Investigation Fees to Date	$9,091.56

  *Investigator retains discretion to determine applicable sections of Code of Conduct Bylaw.

Interim Applications Under the Code of Conduct

• Interim Applications Under the Code of Conduct + Complaint No. 2025-0028

  Date	May 9, 2025
  Subject of Complaint	Mayor Hamer-Jackson complained that the Investigator was biased and should not be permitted to investigate three (3) complaints that the Mayor filed against one or more councillors and one complaint that a councillor filed against the Mayor. Upon receiving the complaints, the Investigator immediately put into abeyance the three active complaints, pending the outcome of the bias review.
  Bylaw Sections Engaged	N/A
  Investigation Fees to Date	$9,534.01

  Conclusion

  • Having conducted a thorough bias review in accordance with the legal process laid out by Canadian courts, the Investigator concluded there was no actual or perceived bias requiring disqualification.
  • The Investigator noted that the Mayor’s allegation of bias was based on his dissatisfaction with outcomes in two prior investigations (#2024-0019 and #2024-0020), where he was found to have breached the Code of Conduct, the Community Charter, and the Freedom of Information and Protection of Privacy Act.
     
    • “To summarize, you submit that I am biased largely because you feel I have conducted previous Code investigations in a manner that is not impartial. In three emails dated May 2nd, you stated that: (1) you feel that my urging you to retain legal counsel is an indication of bias; and (2) I relied on many “assumptions” in investigating complaint 0019. In particular, you are concerned with the conclusions to which I came in 0019 and with my choice of witnesses”.

    • “In another email, dated April 30th, in response to information requests relating to three complaints you filed, you stated: 

      Lol now you want me to do the investigation lol. Just listen to radio Nl Kamloops. Or with Bass just google the dates. Seriously you’re not bias are you ? Who hired you? Specific person. Respectfully Mayor Hamer-Jackson

      While this email is not as detailed as it could be, I take it to mean that you disagree with my information requests, and that you believe those information requests indicate bias.”

  • The Investigator invited the Mayor to provide evidence or submissions on the issue of bias, but the Mayor declined to do so.  
  • Applying the test for reasonable apprehension of bias, Investigator Harding concluded that an informed and objective observer would not perceive bias. 
     

    • “While I was critical of your conduct in these complaints, I did not make comments that were gratuitous or unfounded. […] [W]here a breach is found, there will inherently be some criticism of the person whose conduct is at issue.

      […] I do not believe that a reasonable person, viewing the matter objectively, would find that my criticisms rise to the level of disqualifying bias.”

  • The Investigator also noted he had ruled in Mayor Hamer-Jackson’s favour in other matters.
  • Having found no actual or perceived bias requiring disqualification, the Investigator reactivated the complaints previously held in abeyance.

  Investigator's Decision
   

• Further Application to Council

  Date	June 20, 2025
  Subject of Complaint	Despite the Investigator’s finding that there was no actual or perceived bias, Mayor Hamer-Jackson requested that Council nonetheless postpone his complaint against a councillor (#2025-25), and appoint a new investigator who is a member of the Private Investigators Association of BC.
  Bylaw Sections Engaged	N/A

  Conclusion

  • Council provided advance written notice to Mayor Hamer-Jackson that it would formally consider his request at its July 15, 2025 closed Council meeting. He was informed of his right to have legal counsel present and was given an opportunity to provide evidence supporting his allegations, either in person or in writing, at his discretion.
  • Despite receiving advance notice and an invitation to provide evidence, Mayor Hamer-Jackson absented himself from the meeting without explanation. He chose not to submit any verbal or written statements in support of his allegations or his request.
  • Council considered Mayor Hamer-Jackson’s application at its July 15, 2025 closed meeting and concluded that it has no authority under the Council Code of Conduct Bylaw to intervene in an active Code of Conduct investigation. As a result, Council cannot interfere with the assignment of an independent investigator, as requested by the Mayor.
  • Council went on to conclude that, even if it had the authority to interfere with an ongoing complaint under the Code of Conduct it would conclude as follows:
    • Council would note Mayor Hamer-Jackson’s failure to provide any evidence whatsoever of bias on the part of the Investigator;
    • Council would adopt the findings of the Investigator as set out in his May 26, 2025 letter to Mayor Hamer-Jackson; and
    • Council would conclude that Investigator Harding does not hold a disqualifying bias, either real or apprehended, against Mayor Hamer-Jackson.
       

Complaints Dismissed

• Complaint #2023-0002

  Date	July 2023
  Subject of Complaint	Councillor Neustaeter alleged the Mayor and his lawyer, acting on instructions from the Mayor, discriminated against her on the basis of gender, age, and physical appearance, and that the Mayor "endorsed and perpetuated the misogynistic view with his own statements and support of the position.”
  Bylaw Sections Engaged	3.1, 3.2, 3.8, and, 3.11
  Investigator	Sarah Chamberlain of Southern Butler Price LLP
  Investigation Fees	$8,904 (includes complaints #2023-0001 and 2023-0002)

  Conclusion

  • Complaint dismissed. 
  • The Investigator found that the Mayor cannot be held responsible for the conduct of his lawyer that was not based on his instructions, and that his lawyer's comments do not constitute a breach of the Code of Conduct by the Mayor.
  • This was investigated at the same time as Complaint #2023-0001, and therefore reported together in the below investigation and addendum reports. 

  Investigation Report Addendum Report

• Complaint #2023-0003

  Date	August 2023
  Subject of Complaint	The Complainant (member of the public) alleged the Respondent displayed a lack of decorum in a Council meeting and bullied and harassed another member of Council.
  Bylaw Sections Engaged	3.1, 3.2, 3.3, 3.8, 3.11, and 3.14
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$66,411.46 (includes complaints #2023-0003, 2023-0004, 2023-0005, and 2023-0006)

  Conclusion

  • Complaint summarily dismissed. 
  • The Investigator summarily dismissed the Complaint. No Investigation Report issued.
• Complaint #2023-0004

  Date	August 2023
  Subject of Complaint	The Complainant (member of the public) alleged Councillor Neustaeter breached the Code of Conduct Bylaw by giving a misleading answer when asked by a member of the public at a Council meeting whether there was a meeting of council to draft and edit a statement prior to its public release on March 17, 2023.
  Bylaw Sections Engaged	2.1, 3.2, 3.3, 3.11, and 3.14
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$66,411.46 (includes complaints #2023-0003, 2023-0004, 2023-0005, and 2023-0006)

  Conclusion

  • Complaint dismissed. 
  • The Investigator found that Councillor Neustaeter did not breach the Code of Conduct Bylaw. 
  • The Investigator found that Councillor Neustaeter answered the question honestly and to the best of her ability.

  Investigation Report

• Complaint #2023-0006

  Date	August 2023
  Subject of Complaint	The Complainant (a member of the public) alleged that, by wrongly accusing another member of Council of inappropriate conduct, the Respondent misled the public, undermined the will of Council, and disrespected, bullied, and harassed another member of Council.
  Bylaw Sections Engaged	1.5, 3.1, 3.2, 3.3, 3.11, and 3.14
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$66,411.46 (includes complaints #2023-0003, 2023-0004, 2023-0005, and 2023-0006)

  Conclusion

  • Complaint summarily dismissed. 
  • The Investigator summarily dismissed the Complaint. No Investigation Report issued.
• Complaint #2023-0007

  Date	August 2023
  Subject of Complaint	The Complainant (initially a member of the public, now Mayor Hamer-Jackson) alleged all remaining members of Council improperly disclosed or knowingly acquiesced to the improper disclosure of a privileged and confidential workplace investigation report and other confidential information and records.
  Bylaw Sections Engaged	3.1, 3.3, 3.9, 3.15, and 4.30
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$63,008.01

  Conclusion

  • Complaint dismissed. 
  • Investigation Report issued. However, because Mayor Hamer-Jackson is the Complainant and all councillors are the Respondents, conflict of interest rules prevent Council from considering the Report under s. 4.31(d) of the Code of Conduct as a quorum cannot be formed.

  Investigation Report

• Complaint #2023-0008

  Date	July 2023
  Subject of Complaint	The Complainants (members of the public) alleged the Respondent misled the public by wrongly accusing another member of Council of inappropriate behaviour.
  Bylaw Sections Engaged	3.1, 3.2, 3.8, 3.11, and 3.14
  Investigator	None
  Investigation Fees	None

  Conclusion

  • Complaint summarily dismissed. No Investigation Report issued.
• Complaint #2023-0010

  Date	October 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent neglected or refused to abide by an order imposed by Council.
  Bylaw Sections Engaged	3.3, 3.5, and 3.11
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$3,112.53

  Conclusion

  • See 2023-0015
  • Complaint summarily dismissed. 
• Complaint #2023-0015

  Date	November 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent failed to follow a Council resolution by refusing to attend mandatory respectful workplace training.
  Bylaw Sections Engaged	3.3, 3.5, and 3.11
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$5,378.75

  Conclusion

  • Summarily dismissed. 
• Complaint #2025-0026

  Date	April 2025
  Subject of Complaint	The Complainant (member of Council) alleged that the Respondent made public statements which the Respondent knew or ought to have known were false or misleading and which defamed the Complainant.
  Bylaw Sections Engaged	3.1, 3.2, 3.8, and 3.11
  Investigator	Reece Harding of Young Anderson
  Investigation Fees to Date	$3,698.18

  • Complaint summarily dismissed on the basis that the Complaint contained insufficient detail to conclude that a violation of the Code of Conduct had occurred.
  • The Investigator summarily dismissed the Complaint. No Investigation Report Issued.
• Complaint #2025-0027

  Date	April 2025
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent made public statements which the Respondent knew or ought to have known were false or misleading and which defamed the Complainant.
  Bylaw Sections Engaged	3.1, 3.2, 3.8, and 3.11
  Investigator	Reece Harding of Young Anderson
  Investigation Fees to Date	$2,915.65

  • Complaint summarily dismissed on the basis that the Complaint contained insufficient detail to conclude that a violation of the Code of Conduct had occurred.
  • The Investigator summarily dismissed the Complaint. No Investigation Report Issued.

Complaints Withdrawn

• Complaint #2023-0009

  Date	September 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent bullied, harassed, and mistreated two members of staff at a Council meeting.
  Bylaw Sections Engaged	3.1, 3.2, 3.8, 3.11, and 3.14
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$5,970.54

  Conclusion

  • Complaint withdrawn. 
  • Respondent would not agree to informal resolution and Complainant was concerned about costs of investigation.
• Complaint #2023-0011

  Date	November 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent breached confidentiality and harassed the Complainant.
  Bylaw Sections Engaged	3.1, 3.2, 3.3, 3.11, 3.15, 3.18, and 4.40
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$4,167.31

  Conclusion

  • Clerical error - duplicative.
  • Complaint now addressed in 2024-0020.
• Complaint #2023-0012

  Date	November 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent treated the Complainant disrespectfully in an email with a third party.
  Bylaw Sections Engaged	3.1, 3.2, 3.8, and 3.11
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$583.76

  Conclusion

  • Complaint withdrawn.
• Complaint #2023-0013

  Date	November 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent failed to respect the will of Council.
  Bylaw Sections Engaged	3.3, 3.11, 3.18, and 3.23
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$615.12

  Conclusion

  • Complaint withdrawn.
• Complaint #2023-0014

  Date	November 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent disrespected, bullied, and harassed a staff member at a public City event.
  Bylaw Sections Engaged	3.1, 3.2, 3.8, and 3.11
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$5,256.58

  Conclusion

  • Complaint withdrawn due to fear of indirect or direct retaliation by Respondent against City staff if investigation continued.
• Complaint #2023-0016

  Date	December 2023
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent was disrespectful towards a staff member in a Council meeting.
  Bylaw Sections Engaged	3.1, 3.2, 3.8, 3.11, and 3.14
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$474.93

  Conclusion

  • Complaint withdrawn due to fear of indirect or direct retaliation by Respondent against City staff if investigation continued.
• Complaint #2024-0017

  Date	January 2024
  Subject of Complaint	The Complainant (member of staff) alleged the Respondent made inappropriate comments to staff about a matter in which the Respondent had a conflict of interest.
  Bylaw Sections Engaged	3.2, 3.3, 3.4, 3.5, 3.8, 3.11, 3.18, 3.22, and 3.23
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$1,585.25

  Conclusion

  • Complaint withdrawn due to fear of retaliation by Respondent.
• Complaint #2024-0018

  Date	February 2024
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent attended a community event and aggressively confronted a staff member about a matter in which the Respondent has a conflict of interest.
  Bylaw Sections Engaged	3.1, 3.2, 3.3, 3.4, 3.6, 3.9, 3.14, 3.18, and 3.22
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$3,009.56

  Conclusion

  • Complaint withdrawn due to fear of indirect or direct retaliation by Respondent against City staff if investigation continued.
• Complaint #2024-0021/0022

  Date	September/October 2024
  Subject of Complaint	The Complainant (member of Council) alleged the Respondent repeatedly breached confidentiality and privacy.
  Bylaw Sections Engaged	3.1, 3.3, 3.8, 3.11, 3.15
  Investigator	Reece Harding of Young Anderson
  Investigation Fees	$21,987.56

  Conclusion

  • Complaint withdrawn due to mounting costs associated with investigating numerous alleged privacy breaches.