Conflicts of interest

When you pay someone to represent you, their loyalty should be to you. This page explains how Polinsys spots and handles situations where that loyalty could be divided, and it matters most to workers, employers and families whose files touch one another.

Polinsys acts through its authorized representative, Joy Stephen, RCIC, CICC licence R419719. The rules below come from the Code of Professional Conduct of the College of Immigration and Citizenship Consultants (CICC), which replaced the former regulator, ICCRC. You can check the licence on the CICC public register.

What a conflict of interest is

A conflict of interest exists when something could get in the way of acting fully and only in your interest. It might be another client's interest, a third party's, or our own. Common examples in immigration work:

• acting for two people whose interests could differ, such as an employer and the worker they want to hire, or two members of a family whose plans may part ways;
• acting for someone against a former client, or where we hold confidential information from another file that matters to yours;
• a personal or financial interest of the licensee or a staff member in the outcome;
• recruitment: helping a person find a job while also representing them, or representing an employer while helping it find workers. The Code treats recruitment services as a source of conflict, with only narrow exceptions.

A conflict does not always mean we must refuse. It means we must tell you, and in some cases stop.

How we disclose and ask your consent

The Code says a licensee must not act in a conflict of interest unless it has been disclosed in writing and the client has given free, informed, written consent. At Polinsys that means:

1. We check before we act. When a new file comes in, we look for links to existing and former clients and to employers.
2. We tell you in writing, plainly: who else is involved, what the conflict is, and how it could affect you.
3. We ask for your written consent. You can take time to decide and to seek independent advice. Saying no is always your right.
4. We record it in your service agreement, which lists any conflict disclosures, and we tell you if a new one arises while your file is open.

When we cannot act

Consent is not always enough. Even with written consent, we will not act, or will stop acting, when:

• we cannot stay objective for each client;
• we cannot keep each client's confidential information from the other;
• the trust between us and either client cannot be maintained;
• the two clients' interests have become directly opposed.

If we have to step back, we tell you in writing, return your documents, account for any money held for you, and help you move your file to another authorized representative.

The Code also forbids certain relationships outright, whatever the consent. We do not lend money to clients, do not enter unrelated business dealings with clients, and do not allow personal or intimate relationships between the licensee and clients.

Work involving both an employer and a worker

Employer-driven pathways, such as a provincial employer stream, the Atlantic Immigration Program or a work permit supported by a Labour Market Impact Assessment (LMIA), bring an employer and a worker into the same file. Their interests often line up, but not always: wages, duties, the length of the commitment, and what happens if the job ends. Our rules:

• If we ever act for both an employer and a worker on the same matter, we disclose that in writing to both and ask for both parties' written consent before we do any work. Each party is told what we can and cannot share with the other.
• We never charge a worker a recruitment fee. A worker pays only for the immigration services set out in their own written service agreement.
• We never buy, sell or broker job offers or LMIAs. IRCC describes the buying and selling of LMIA applications as fraud. Anyone who asks you to pay for a job offer or an LMIA should be reported, not paid.
• We never place a worker's interests below an employer's on any matter where we represent the worker. If that cannot be avoided, we stop acting for one or both.

Workers looking for jobs should find them directly with employers. Our page on job offers and employer-driven permanent residence explains how these routes work.

Family files

Family members often apply together, and usually their interests are the same. Where they may not be (a sponsorship after a separation, or adult children whose plans differ from their parents'), we explain the possible conflict to each adult in writing, and each adult gives their own consent.

If you think we have a conflict

Raise it with us at [email protected] or through the form below, and we will reply in writing. You may also complain to CICC directly through its online portal. See Complaints.

How Polinsys helps

• A conflict check on every new file, before the service agreement is signed.
• Plain written disclosures, so you know who else is involved and what it means for you.
• No recruitment fees, no job offers for sale, and the licensee available to answer questions directly at the free Friday Q&A. See FREE Webinars: Resource Guides and AR Q&A.

Read about our wider integrity commitments.