Compliance Agreements

On June 23, 2020, the Commissioner of Canada Elections and Norda Stelo Inc. signed an addendum modifying the compliance agreement they entered into on April 3, 2020. One of the installments to be made by Norda Stelo Inc. to the Receiver General of Canada as part of the terms and conditions of the compliance agreement has been postponed to a later date. The full text of the addendum is available at the following link: Addendum – Norda Stelo Inc.

Commissioner Of Canada Elections

Canada Elections Act

Compliance agreement

This notice is published by the Commissioner of Canada Elections, pursuant to section 521 of the Canada Elections Act, S.C. 2000, c. 9, as amended.

On April 3, 2020, the Commissioner of Canada Elections entered into a compliance agreement with Norda Stelo Inc., pursuant to section 517 of the Canada Elections Act. The text of the compliance agreement is set out in full below.

May 19, 2020

Compliance Agreement

Pursuant to section 517 of the Canada Elections Act (the Act), the Commissioner of Canada Elections (the Commissioner) has entered into this compliance agreement with Norda Stelo Inc. (the Contracting Party) to ensure compliance with this Act.

The provisions of the Act applicable at the time the events occurred were subsections 404(1), 405.2(1) and 405.2(2). Subsection 404(1) of the Act prohibited any person or entity other than an individual who is a Canadian citizen or permanent resident of Canada from making a contribution within the meaning of the Act. Subsection 405.2(1) of the Act prohibited any person or entity from circumventing or attempting to circumvent this prohibition or acting in collusion with another person or entity for this purpose. Lastly, subsection 405.2(2) of the Act prohibited any person or entity from concealing or attempting to conceal the identity of the source of a contribution, or acting in collusion with another person or entity for this purpose.

Sections 404 and 405.2 were re-enacted by S.C. 2014, c.12, and correspond to current sections 363 and 368 of the Act.

Statements by the Contracting Party

For the purposes of this compliance agreement, the Contracting Party states the following:

Factors considered by the Commissioner

Taking into account the factors set out in section 32 of the Compliance and Enforcement Policy of the Commissioner of Canada Elections, the Commissioner is of the opinion that entering into a transaction is, in the circumstances, the most appropriate way to conclude this matter in the public interest as it relates to the Contracting Party and to ensure enforcement of and compliance with the Act. In particular, the Commissioner considered the following factors:

Undertakings and agreement

The Contracting Party undertakes to post on its premises, for a period of 30 days following the signing of this compliance agreement, such that it is visible to all employees who work there, a memorandum approved by the Commissioner announcing the conclusion and contents of this compliance agreement, as well as the Contracting Party’s undertaking to comply with the relevant provisions of the Act and provide a report in this regard to the Commissioner, at the latest within 30 days after the posting of the memorandum.

The Contracting Party undertakes to publish, within 30 days of signing the compliance agreement, a notice entitled “Norda Stelo Inc. signs a compliance agreement with the Commissioner of Canada Elections concerning political contributions made at the federal level between 2004 and 2011 and undertakes to continue to comply with the Canada Elections Act” (notice of compliance agreement), bearing the Contracting Party’s logo and reproducing the exact terms preauthorized by the Commissioner in a wide-circulation, French‑language newspaper in Quebec (for the notice in French) and a wide-circulation, English‑language newspaper in Quebec (for the notice in English), to be published on a Saturday in a format acceptable to the Commissioner.

The Contracting Party undertakes to post, at the top of its website home page, in English and in French, for a period of 30 days following the publication of the compliance agreement on the Commissioner’s website, a clear and legible hyperlink entitled “Norda Stelo Inc. signs a compliance agreement with the Commissioner of Canada Elections for illegal federal political contributions made between 2004 and 2011” which leads to the full text of the notice of the compliance agreement described above.

The Contracting Party undertakes to give written notice to its executives, as well as all members of its board of directors, of the signing and scope of this compliance agreement by providing them with a copy of the notice appended to this compliance agreement, electronically or otherwise, within 10 days following the signing of this compliance agreement.

The Contracting Party undertakes to provide written evidence to the Commissioner, within five days following the notice given, pursuant to the preceding paragraph, to its directors and current board members, that they were given this notice.

With regard to executives or board members hired or appointed by the Contracting Party in the six months following the signing of the compliance agreement, the Contracting Party undertakes to notify them in writing, electronically or otherwise, of the signing of the compliance agreement and to provide them with a copy of the notice of the compliance agreement described above at the time of hiring or appointment. Within the same timeframe, the Contracting Party shall provide the Commissioner with written confirmation of its compliance with the requirements set out in this paragraph.

In accordance with subsection 517(2) of the Act, the Contracting Party undertakes to pay to the Receiver General for Canada an amount of $139,660.23, representing three times the amount of the contributions in question.

Taking into consideration that financial situation of the Contracting Party and the level of cooperation it has shown in this matter, the Commissioner has consented to the Contracting Party’s repayment of the amount outlined in the preceding paragraph in four installments. These installments are to be made by certified cheque or bank draft payable to the Receiver General of Canada and remitted to the Commissioner in accordance with the dates and amounts outlined below:

The Commissioner agrees that the fulfillment by the Contracting Party of the conditions described in this compliance agreement will constitute compliance with the agreement.

In accordance with subsection 517(5), the Commissioner and the Contracting Party acknowledge that the compliance agreement and statements it contains are not admissible as evidence against the Contracting Party in any civil or criminal proceedings.

The Commissioner agrees that the Contracting Party will have complied with this compliance agreement when it has satisfied the requirements contained therein.

In accordance with subsection 517(8) of the Act, the Commissioner and the Contracting Party acknowledge that when a compliance agreement is entered into, neither the Commissioner nor anyone else can institute criminal proceedings against the Contracting Party for the facts that are the subject of the compliance agreement, unless the Contracting Party is found to be in non-compliance with the compliance agreement.


Signed by the Contracting Party in the City of Québec, in the Province of Quebec, this 27th day of January 2020.

Alex Brisson,
President and Chief Executive Officer
Norda Stelo Inc.

Signed by the Commissioner of Canada Elections, in the City of Gatineau, in the Province of Quebec, on this 3rd day of April 2020.

Yves Côté, QC
Commissioner of Canada Elections

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