The SNC-Lavalin Affair- Part II


Gerald Butts testimony before the House of Commons Justice Committee

The House of Commons Justice Committee is not a court of law.

This is obvious to everyone who has watched the recent testimony before that body.  Because the Committee is a political body, it is an extension of the ruling party, and it’s deliberations are not a search for the truth.  It is a Liberal dominated Committee hell-bent on  establishing political cover for the actions of the Liberal government.

The Committee however has some of the trappings of a court of law.  It calls witnesses and hears testimony but at the end of the day it does not reach any conclusions or make any rulings.

In short it is a political exercise.

The role of Mr. Butts at the Committee

If one were to draw parallels between the Committee hearings and a court of law it might look like this.

Ms. Wilson-Raybould was the complainant,  the prime witness for the prosecution.  She testified as to the alleged wrong doing perpetrated  by the Prime Minister, the PMO, the Clerk of the Privy Counsel and others in their attempt to interfere with her duties as the Attorney General in an attempt  influence the course of justice.

Mr. Butts appeared for the defence, in this case his own defence and defence of the government and its officials and most importantly in defence of the Prime Minister.

As in a court of law the defence does not need to prove that they (the accused) did not do what they are accused of.

All they need to do is raise a reasonable doubt and that was what Mr. Butts was there to do.

In the case of Mr. Butts all he needed to do was muddy the waters.  Because of the political realities he took great case not to attack Jody Wilson-Raybould, an Indigenous woman.  He nibbled around the edges and attempted to raise doubts, to muddy the waters.

In a court of law if reasonable doubt is raised the accused is entitled to an acquittal.

In the case of the Justice Committee there is no true trier of fact so at the end of the day, no ruling was rendered.

Members of the Justice Committee on all sides essentially have their minds made up and can be expected to arrive at conclusions drawn along party lines.


Was doubt raised

From the press coverage of the Prime Minister’s subsequent comments to the media it would appear that he is convinced that his friend Mr. Butts succeeded in raising sufficient doubt and he is now parroting Mr. Butts’ mantra of confusion and misunderstanding, but no wrongdoing.   Mr. Butts muddied the water and the Prime Minister is the straw now stirring the muddied water in an attempt to  ensure the sediment does not settle.

Mr Butts was a competent witness and performed well in terms of adding confusion to the issue.  However,  it will not take long for the sediment stirred up by Mr. Butts to settle to the bottom.  In my view this attempts at muddying the water succeeded but only on a  temporary basis.  As he stated in his testimony  “facts are stubborn things”.

Facts  are indeed stubborn things and the facts presented by the former Attorney General  stand tall and speak for themselves, untarnished, untainted and powerful.

They will survive the current Liberal onslaught and survive in the minds of Canadians who in this case are the true triers of fact.

Canadians will render their decision on this matter on October 21st. 2019.

Strategic Planning in Policing – Part II

Planning – The Process

Planning is by definition a future oriented activity.  If an organization is satisfied with what it is currently doing and how they are doing it there is no need to plan. It’s simply a matter of maintaining the status quo. A plan is only required in situations where the destination or outcome is at variance with the status quo.

There has been much discussion among academics and practitioners alike as to what comes first in terms of the strategic planning process.  Although there is general agreement that strategic plans should include a vision statement, mission statement and core values, there is less agreement as to how they should be arrived at.

Many instances of major organizational change involve change at the top in terms of leadership.  In such scenarios leaders are frequently chosen based on their vision of the future of the organization.  In such instances the leader’s vision becomes the organization’s vision.  In terms of policing organizations the hiring of a new leader (chief) generally signals such a change which is usually accompanied by the introduction of a 1oo day, 6 month and 1 year plan outlining the new direction of the organization.

In situations where a leader is chosen to essentially be a caretaker of an organization and there is no anticipation of major organizational change, the emphasis will shift from strategic planning to greater attention of operational issues designed to maintain the status quo.

The alternative approach is to develop the vision and mission from within the organization based on the collective will of the organization (employees).  This is a slow, time consuming process.  In many instances organizationally developed plans are watered down plans that attempt to please everyone and in the end please no one.  This committee style of approach often results in the production of a ‘camel’ (a horse designed by a committee) as various groups and individuals add on humps and lumps to the original design.

Environmental Scanning

Dr. Chun Wei Choo (University of Toronto) provides the following definition of environment scanning: Environmental scanning is the acquisition and use of information about events, trends and relationships in an organization’s external environment, the knowledge of which would assist management in planning the organization’s future course of action.

There is general agreement that conducting a complete in-depth environmental scan is essential as a first step in the strategic planning process.  Private industry has successfully used this technique for decades to gain a competitive advantage.  Police departments, although a monopoly, can use the approach to improve performance and seek and establish an advantage in relation to criminals and criminal activity.

Environmental scans can be undertaken using various approaches or formats but some of the most common approaches center on the SWOT approach.  SWOT is an acronym for strengths, weakness’, opportunities and threats.  The strengths and weakness aspect deals with issues internal to the organization and would look at things like the size, training and level of commitment of the workforce, status of leadership within the organization at all levels,  and adequacy of existing policy.  The opportunity and threats analysis would examine issues such as synergies, partnerships and working relationships that could be developed along with threats to the organization.  As indicated in the table below, a SWOT analysis concentrates on identifying internal and external factors that are either helpful or harmful to goal achievement.

SWOT ANALYSIS MATRIX Helpful to goal achievement Harmful to goal achievement
Internal Strengths Weakness
External Opportunities Threats

There are other environmental scanning models such as the PESTEL analysis which examines political, economic, technological, legal and socio-cultural factors.  The analytical needs of an organization best determine the choice of an analytical model.  The issue is not which model you use but rather that you perform a systematic in-depth environment scan.  Because the field of medicine has been a leader in terms of implementing the scientific approach, let me use a medical analogy here:  formulating a strategic plan with goals, objectives, strategies and tactics without first doing a complete environmental scan would be akin to a doctor prescribing a drug or course of treatment prior to obtaining a complete medical history and doing an examination and perhaps tests on a patient.  Medical examinations and environmental scans identify symptoms and causes and form the basis for ‘treatment’.

The Nuts and Bolts of a Strategic Plan

What follows is a list of the key components incorporated in most strategic plans prepared by police agencies:

Vision Statement – The vision statement incorporates the desired end state or destination visualized by leadership of the organization.  It expresses what the organization wants to be or where it wants to be. Vision statements are not intended to be prescriptive in terms of how the organization will achieve its desired end state.  Prescriptive vision statements tend to limit the strategic options either available to or considered by the organization.

The very best vision statements are brief and to the point.  Ideally every member of the organization should be able to tell you what the organizations vision is.  If they cannot, then how can they be said to be working toward the vision?  Brief but meaningful vision statements are easily remembered and easier for individual members of the organization to incorporate into their personal raison d’être.

Mission Statement – In a private sector context mission statements generally address three issues -what is it that the organization does, who are the stakeholders or target audience, and what distinguishes this particular organization from all others, i.e. what is it about this organization that creates a competitive advantage.  Because public sector organizations such as police departments are monopolies and provide services to the entire public at large, identifying stakeholders and creating a competitive advantage as such are not an issue.  Creating and delivering a high quality of service is incumbent on all monopolies.

Let’s turn then to the first aspect of the mission statement, that being, describing what the organization does. Why is this so important?  It is important to ensure that there is agreement between the organization and the stakeholders as to what the mission is. In a police setting if the organization sees its mission as something else than what the stakeholders expect, there will be unfulfilled expectations and friction between the police and the public. That is why it is so vitally important that a police department have a clear mission statement that reflects the wants and needs of the stakeholders which in this context includes the public, elected officials and the members of the organization.

Core Values- In Canada we have incorporated into our constitution a Charter of Rights and Freedoms. The Charter is the prime law of the land.  This means that any law that violates the charter can be challenged as being unconstitutional.  If a law is deemed unconstitutional the portions of the law that are unconstitutional are deemed null and void.

The core values of an organization essentially form its internal charter of rights and freedoms, it’s prime law.  Organizations that are truly committed to their core values will ensure that all its policies and procedures are in keeping with its core values.  It will ensure that the actions of its members, especially the leadership cadre reflect the core values.  It will ensure that policies that violate the core values are amended, and that members of the organization whose actions violate the core values are censured or disciplined in a meaningful manner.  Every violation of the core values that is not addressed weakens the core value.

Core values in both private and public organizations are largely universal and center on values such as honesty, integrity, openness, trust, respect and accountability.

The next post will deal with the remaining components of a strategic plan.


Strategic Planning in Policing – Part I

This is the first in a series of posts that will deal with the strategic planning process.

This post will briefly discuss the impetus that led to the emergence of strategic planning in the public sector.

Part II will discuss the strategic planning process and component parts of a good strategic plan.

Part III will examine current strategic plans from various Canadian police departments and highlight the strengths and weaknesses of some of their strategic plans.

Strategic Planning in the Public Sector

Strategic planning is not  a new concept.  Many police departments in both Canada and the United States engaged in strategic planning in the late 1980’s and early 1990’s.  Many of these early attempts at strategic planning, albeit rudimentary in nature, served a useful purpose in terms of focusing police executives on their raison d’être.  The weakness of many early strategic plans was that they were stand alone plans that did not integrate the planning process with the budget process.

The Advent of New Public Management (NPM)

New public management, although difficult to define, centers on the notion of introducing aspects of private sector management ideas and methodologies in the public sector.  Moves in the 1980’s by politicians in England and the United states, namely by Margaret Thatcher and Ronald Reagan, to privatize and deregulate key sectors of government and industry gave incentive to public sector administrators to look seriously at introducing private sector approaches in the public sector.

In terms of a movement, NPM received its biggest shot in the arm when Vice President Al Gore published Creating a Government That Works Better & Costs Less: Report of the National Performance Review.  This report and the subsequent approach taken by the Clinton/Gore  administration essentially turned public management on its ear.  The orignal report and subsequent departmental performance reports provided examples of government waste, outdated practices, lack of accountability and poor performance.  The move to NPM introduced to government and public administrators, private sector approaches in many areas of management such as human resource management, procurement and perhaps most importantly in the policing context, strategic planning. 

Private sector businesses and corporations which are driven by the free enterprise economy and competition have long understood that unless they are involved in a constant cycle of renewal, innovation and  reinvention the bottom line will suffer and they will become redundant.  In the private sector this resulted in significant downsizing during the 1980’s and 90’s and the creation of ‘lean mean’ companies that were nimble in terms of their ability to predict and respond to economic conditions,  market trends and consumer needs. 

Many publicly funded government sector organizations on the other hand maintained the status quo, labouring under ever-increasing regulation and self-imposed policies and procedures that stifled productivity, innovation and service delivery.  Flaws in the system were not addressed by stream lining  processes but rather by the addition of new restrictions by way of regulations or procedures that further bogged down the ability of the public sector entities to deliver services.  In the previously cited report, Vice President Gore described it as “good people trapped in bad systems”. 

The NPM movement introduced strategic planning to the public sector as one of the lynchpins of public sector reform that offered great promise in terms of revitalizing public sector entities and improving their performance. 

 A Process – Not An Event

Some police and other public sector executives do not fully comprehend that strategic planning is a process, not an event.  Some organizations develop a 3 or 5 year strategic plan and once they have completed the plan document they heave a sigh of relief, grateful that it is out-of-the-way.  They fail to comprehend that the initial development of a strategic plan is just the first step in a cyclical process that must at a minimum be revisited, assessed and in many cases modified on an annual basis and in some cases more frequently. 

Foot Patrols Part III – The Pre-Community Policing Era

In the late 1970’s and early 1980’s, Winnipeg was at the very cutting edge of what later came to be known as Community Policing.  It was dubbed Operation Affirmative Action  (OAA).

OAA incorporated many of the principles and values first proposed by Sir Robert Peel when the London Metropolitan Police Force was formed in 1829.  OAA was an approach to policing that recognized the importance of forming partnerships between the police and the community at the local level.  Hence it was structured on a geographical basis.  It was an early  form of Zone Policing that was later popularized by many Canadian and American cities under the banner of ‘Community Policing’.

The main tenets of OAA were:

  • permanent long-term assignment of  patrol unit and beat personnel to specific geographical areas;
  • the use of problem solving as opposed to a strictly legal approach to dealing with issues at the community level;
  • being proactive in terms of developing a working partnership with residents and business people on the an officer’s assigned beat and patrol unit area as well as addressing local community issues in their early stages before they developed into full-blown community problems.

The concept was a sound one but ahead of its time.  The OAA approach represented a radical departure from the policing norms of the day in terms of values, goals and approaches.

Officers assigned to beat patrol received very limited training and for the most part continued doing beat patrol in the same manner as they had in the past.  The proactive side of the equation was not sufficiently explained to either beat personnel or members assigned to mobile patrol units.  The entire operation was administered by a Staff Sergeant and without any apparent support by the police executive of the day, many officers took and expressed the attitude “this too shall pass” and failed to buy into the initiative.

Lastly, the police executive of the day was not prepared to give up decision-making power or control to the officers working at the street level.  This attitude  prevented the a proactive approach central to the success of OAA from taking hold.

Like many good ideas OAA  suffered from insufficient executive commitment,  inadequate pre-implementation  training and a general lack of post-implementation  nurturing.

As a consequence OAA died on the vine.

Part IV will deal with foot patrols during the community policing era which was kick started with the publication of a discussion paper titled A Vision of the Future of Policing in Canada, published by the Solicitor General of Canada in 1990.

The Benefits of Openness and Transparency in Policing

One of the keys to the development of positive relations between the police and the community is the creation of a culture of openness and transparency in policing.

During my many years as a police officer I found that when police explain what they are doing and why they are doing it, all but a few members of the public (and the media) ‘get it’. They may not always agree but they recognize and understand the rationale.

What is required from police is a willingness to be open and transparent. Police departments have been and continue to be secretive about almost everything they are involved in. Unless, of course, they are looking for media coverage of positive stories or they need media assistance in getting out a message about a particular case where they need information from the public to solve the case.

Greater openness and transparency on the part of police departments would go a long way to improve the police image in the eyes of the public. It would also provide a greater measure of accountability.

Lets look at an example: there are few issues in policing that create more heated debate than police use of force. Police departments are seldom taken to task for high crime rates, low clearance rates or the like. But, an instance of police use of force, especially if captured on video (such as the Rodney King incident in Los Angles, the Robert Dziekanski incident in Vancouver or the Cody Bousquet case here in Winnipeg) focuses public attention on the actions of police.

One of the main issues when these types of incidents come to the public’s attention is that the public, and to a lesser extent the media, are ill-informed about what police department policies are in relation to use of force.

There are several approaches that can be taken to address  issues like this in a proactive way. One is to create greater transparency in terms of police policies and procedures. If, for example, both the public and the media are fully aware of the police department’s use of force policy, and the policy is a public document, a lot of speculation and misinformation could be avoided.

Secondly, if police departments conducted information sessions explaining their policies both for the media and the public, the resulting dialogue would eliminate many of the misconceptions that exist.

Some police departments such as Vancouver and Portland, Oregon have put their procedure manual on-line – a bold and progressive step.

Police in Oakland, California recently invited the community and the media to a seminar that outlined the use of force training received by members of the Oakland Police Department. The seminar dealt with both the legal use of force framework, as well as hands on demonstration of video simulator training.

Initiatives such as these reinforce openness, transparency and accountability to the public on the part of police and create positive dialogue between the public and the police.

Note: The Oakland Police Department has also opened its CompStat meetings to the public.

Taking Care of Business in the North End: Again

While the  crime rate (for the crimes types reported on Crimestat) in north Winnipeg (police District 3) is basically static a study of specific north end neighbourhoods shows a much different picture.  Crime in neighbourhoods in close proximity to William Whyte is showing a disturbing trend.  The crime rate in these high crime neighbourhoods is rising, in some case dramatically.

The recent multiple shootings in the north end have again focused attention on this part of the city.  It is unfortunate that the only time these high crime neighbourhoods get attention is in times of tragedy.

The map below depicts the crimes tracked on Crimestat for the south-east portion of District 3.

Source:  Winnipeg Police Crimestat

The crime rate in these neighbourhoods is such that the icons depicting the various crimes overlap each other and it is difficult to appreciate the severity of the problem.  For the sake of clarity one needs to eliminate some of the crime types.  The image below illustrates the violent crimes (murder, shootings, robberies and sexual assault) for the area in question.

Source:  Winnipeg Police Crimestat

A further examination of the crime trend in seven specific north end neighbourhoods shows the following increases:

Neighbourhood 2010 Year to Date October 2009 toOctober 2010
William Whyte 1% 5%
Dufferin 11% 18%
Burrows Central 15% 13%
Robertson 25% 25%
Inkster-Farady 38% 30%
St. John’s 23% 26%
Luxton 16% 32%

Source:  Winnipeg Police Crimestat

The important issue with these data is not so much the actual increase but rather the trend they represent.  Increased crime in high crime neighbourhood or a cluster of neighbourhoods clearly demonstrates the area is not-self sustaining and needs help.  The approach currently employed in these neighbourhoods is not working

The north end communities clustered around the William Whyte have received sporadic attention over the past couple of years usually related to tragedies such as shootings and homicides.  When tragedies occur everyone (the police, the mayor and other civic and provincial politicians and the media) expresses outrage and vows are made to leave no stone unturned to bring the killer(s) to justice.  As indicated in a previous post the police flood the area with additional personnel and the hunt is on.

Such a sudden influx of police resources is in and of itself not a bad strategy, in the short-term.  It becomes problematic when it is the only strategy.  Flooding high crime neighbourhoods with additional police resources drawn from other areas (operational and geographic) is not a sustainable strategy nor is it a strategy that addresses the long-term needs of the neighbourhood and its residents.

Earlier this year police resources were shifted from the north end (and other parts of the city) to the west end to deal with shootings there.  Now resources are being shifted away from the west end back to the north end.  This endless cycle of shifting  resources to deal with emergency situations that crop up is symptomatic of a poorly planned (or unplanned ad hoc and reactive) approach to dealing with crime in high crime neighbourhoods.

The secondary flaw in the constant shifting of resources strategy is its reliance on using a strict law enforcement approach to address a much broader social issue.  You may be able to apply a strict law enforcement approach and arrest you way out of a purely law enforcement issue but you cannot arrest your way out of a social issue.

The problem is that many tradition bound police executives are tethered to the strict law enforcement approach.  They are not adequately familiar with cutting edge approaches to neighbourhood redevelopment and neighbourhood capacity building. Many don’t see that as a policing function.  It may not be a policing function in the strict sense of the word, but what neighbourhood capacity building does is it empowers people and helps prevent crime.  Based on the policing principles laid down by Sir Robert Peel (which in my view are still very applicable today) the prime mandate of the police is crime prevention.

The important issue is not how you strengthen neighbourhoods and reduce and prevent crime but rather that you do it. For high crime neighbourhoods in Winnipeg if that means the police need to go down ‘the road less travelled’, then let the journey begin.

The nature of the issue (problem) must dictate the approach.  As well the nature of the issue must determine the timeline.  Complicated social issues cannot be resolved using simplistic short-term strategies and tactics.

The question is this:  is the Winnipeg Police Service willing to make the leap from using a traditional short-term reactive law enforcement approach to dealing with issues in high crime neighbourhoods to using a long-term proactive approach?

The Service certainly has the tools, the personnel and the budget to make it happen.  The question is: do they have the will?

Investigation of Complaints Against Police Officers

B.C. Chief takes the lead.

In a move that demonstrates vision, foresight, and a true commitment to openness and accountability Vancouver Police Chief Jim Chu is urging the British Columbia  government to expand the investigative mandate of the proposed civilian oversight agency.

As it now stands the proposed agency would only investigate in custody deaths and incidents that result in severe injury.  Based on past experience Chief Chu estimates that the proposed agency’s current mandate would limit its investigations to an average of 4 annually in relation to the Vancouver police.

Although Chu feels that the Vancouver Police are fully capable of conducting competent and unbiased investigations internally,  his suggestion is a recognition that with issues such as the police investigating themselves,  perception is reality.  Investigation by an external body would remove the perception of bias.

Honesty and Trust No Longer Winnipeg Police Core Values

Commitment to Excellence also eliminated as  a core value

Although the changes may not  be readily obvious to the public in terms of how the Winnipeg Police Service operates, the Service made the decision to alter its Vision and Mission statements  a few months ago.  At the same time, the core values of the organization were changed.

The core values of an organization are intended to be fundamental values that serve as reference points for operational decision making on the street and administrative decision making at the executive level.

The following core values have been eliminated:

  • Honesty – Being truthful and open in our interactions with each other and the citizens we serve
  • Trust – Being honourable and maintaining a high level of trust with each other and the members of our community
  • Commitment to Excellence – Adhering to a strict standard of conduct and performance in everything we do

The core values that were nominally retained are integrity, respect and accountability although the definitions applied to the terms have been altered.

Added as  core values are:

  • Citizen Focus – Conducting ourselves in a professional manner at all times, showing pride in service and commitment to serve the greater good.
  • Courage – Serving on the street and in leadership roles, being ready to make tough decisions to valiantly protect people and their property

The mission statement has also changed.  The new Mission Statement for the Winnipeg Police Service is as follows:

As members of the Winnipeg Police Service , we are committed to making Winnipeg safer by:

  • Performing our duties with integrity, compassion and respect,
  • Building strong, trusting relationships with the community because we can’t do it all alone,
  • Enhancing our effectiveness so we can be there when we’re needed the most, and
  • Finding innovative ways of delivering our services.

Lastly the Service’s vision statement has been changed.  The vision now is:

A safer community, built on strong, trusting relationships

Reactions from within the Service are mixed and varied ranging from indifference to complaints that the process used to establish the new vision,  mission and values was exclusionary and did not allow for street level input (constables and sergeants).  Some within the Service also suggest that the `building relationships` phrase is getting a little tired.  Poorly defined terms, especially when overused, risk losing their meaning and credibility.  There is a difference between a slogan and a philosophy and in this case that difference has never been convincingly established.

Changes to an organization`s vision, mission and values are usually a precursor to the development and unveiling of a comprehensive strategic plan.  Such a plan would generally include goals, strategies and measurable performance indicators.  It is not known if the Winnipeg Police Service  developed strategies and performance indicators.  If they have not, then the vision and mission statements are essentially meaningless.

For an example of a well developed strategic plan visit the Vancouver Police website at :

Click to access vpd-strategic-plan-2008-2012.pdf

Winnipeg Police Cars to Sport a New Colour and Logo

Community Commitment is out, ‘Building Relationships’ is in.

Members of the Winnipeg Police Service have been asked to participate in a selection process to choose a new ‘look’ for Winnipeg Police patrol units.  The process will involve members visiting Policenet, logging in and casting a vote for one of two designs.

The new look will feature a black on white as opposed to blue on white color scheme.

The colour is not all that’s being altered.  The Police Service’s long standing motto “Community Commitment” will be removed and replaced by the current administration’s favorite buzz words.  You guessed it, patrol units will be adorned with “Building Relationships”.

It is not anticipated that the words “Community Commitment” will be removed from the Police Service badge.  The heraldic design and wording  incorporated in the badge was personally approved by the Queen.  Any change to the badge would require royal approval.

According to a recent email sent to all members of the Police Service by the Chief,  the new colour scheme and logo is designed to enhance safety in terms of greater visibility, improve the image of the Service, and increase officer morale.

The two proposed patrol unit designs are shown below.

Maintaining the Public Respect

Some Short Term Pain for Long Term Gain

A recent column by Kevin Engstrom in the Winnipeg Sun caused me to reflect on an earlier post  dealing with the issue of police retaining the respect of the public.  It fits in well with Sir Robert Peel’s second principle which says:

To recognize always that the power of the police to fulfill their functions and duties is dependent on public approval of their existence, actions and behaviour, and on their ability to secure and maintain public respect.

Retaining the respect of the public is best achieved through openness, transparency and accountability.  If the police set and apply a different standard for dealing with members of the Service than would apply to a member of the public, the Service is well on its way to sliding down the slippery slope  of ethical decay and abandonment of their sacred public trust.

Some police agencies actually have a specific section in their media policy that deals with the release of information as it relates to police members who are charged criminally.  In most instances these policies require immediate release of information such as the officer’s name, rank, years of service, the charge as well as the officer’s current status with the Service.    That removes the temptation  to withhold information or any  attempt to ‘time’ the release so as to mitigate what the organization might see as negative media coverage.  In the long run the public support and respect garnered through openness and transparency  far outweigh any potential negative consequences.  The public is generally willing to accept that there will be limited instances of criminal activity by police officers.  They do, however, want to be assured that such behavior will not be tolerated and will be dealt with quickly, openly and fairly.  In other words:  that the police service is prepared to clean its own house.

Based on  Mr. Engstrom’s example, the Winnipeg Police Service would not appear to  have the appropriate media release policy in place, that is, one that requires immediate release of  pertinent information when an officer is charged.  Conversely, if they do have such a policy but are choosing to ignore it, then their behavior is  beyond merely ‘ethically sketchy’.

Either way, it’s a problem.

The below link is to Mr. Engstrom’s column.