Use of City of London Resources for Election Purposes

Legislative History: Adopted October 30, 2017 (By-law No. CPOL.-230-519); Amended July 24, 2018 (By-law No. CPOL.-230(a)-405); Amended August 27, 2019 (By-law No. CPOL.-230(b)-231); Amended, June 3, 2025 (By-law No. CPOL.-230(c)-187)

Last Review Date: June 3, 2025

Service Area Lead: City Clerk

1. Policy Statement

1.1 This policy establishes rules and procedures on the use of City of London resources during municipal, school board, provincial, and federal election campaign periods, including any campaigns related to a question on a ballot. Without exception, all parties shall adhere to the applicable provisions of the Municipal Elections Act, 1996, the Election Finances Act, 1990 and the Canada Elections Act, 2000,the Declaration of Office for Members of Council, the Code of Conduct for Members of Council, and the Code of Ethics (for City employees) regarding the use of City Resources.

1.2 This policy is in accordance with section 88.18 of the Municipal Elections Act, 1996.  The Election Finances Act, 1990 and the Canada Elections Act, 2000 include similar prohibitions with respect to provincial and federal election campaigns. Specifically, section 29 of the Election Finances Act, 1990 prohibits contributions from corporations, which includes municipal corporations. Section 363 of the Canada Elections Act, 2000 similarly provides that only individuals may make campaign contributions.

1.3 This policy sets out provisions for the use of City Resources to indirectly or directly benefit an Election Campaign, to preserve the integrity in the elections process and to comply with the Municipal Elections Act, 1996, the Election Finances Act, 1990 and the Canada Elections Act, 2000. This policy allows the City to satisfy its legal responsibility to ensure that no Candidate, registered Third Party Advertiser or political party is provided with an unfair advantage.

1.4 Nothing in this policy is intended to prohibit a Member of Council from performing their role as an elected official to represent the interests of their constituents regarding City business, during their period of office.

2. Definitions

2.1 For the purposes of this policy

Campaign-related Activities shall mean any activities that may directly or indirectly benefit an Election Campaign.

Campaign-related Signs shall mean any material, regardless of format, that promotes, supports, or opposes any Candidate, Third Party Advertiser or a question on a ballot, or any material that may directly or indirectly benefit an election campaign.

Candidate shall mean any person who has filed and not withdrawn a nomination   for an elected office at the municipal, school board, provincial or federal level in an election or by-election.

City shall mean The Corporation of the City of London.

Election Campaign shall mean any campaign related to an election or by-election at the municipal, provincial and federal level of government, or a campaign related to the submission of a question on the ballot. 

Election Period shall mean the official election campaign period as determined by the Municipal Elections Act, 1996, the Election Finances Act, and the Canada Elections Act as the context requires.

Local Board shall mean a local board as defined in the Municipal Elections Act, 1996.

Restricted Period shall mean a defined period in a municipal and school board election or by-election during which there will be restrictions on certain services and activities provided to Members of Council.  For a municipal election, the Restricted Period begins at 12:01 AM 60 days before Voting Day in relation to the occurrence of a municipal election or by-election. 

Third Party Advertiser shall mean any individual, corporation or trade union registered in accordance with section 88.6 of the Municipal Elections Act, 1996, section 37.5 of the Election Finances Act, 1990, or section 353 of the Canada Elections Act, 2000.

3. Applicability

3.1 This policy shall apply to the use of City resources by any Candidate or political party in a manner that would directly or indirectly benefit a municipal, school board, provincial, or federal Election Campaign or campaigns related to a question on a ballot.

3.2 This policy applies to all Members of Council, City employees, and Council-appointed citizen members of Community Advisory Committees.

3.3 This policy, where applicable, shall also apply to activities of all Candidates, Third Party Advertisers and ballot question campaigns in relation to city resources.

4. The Policy

4.1 Prohibition of Election Activities at City Facilities 

a) No Candidate or political party may rent or use City or Local Board owned facilities for a meeting that would directly or indirectly benefit an Election Campaign or for any election-related purpose. All-candidate meetings are an exception to such prohibition and may be held at City facilities on payment of the rental fee for such facility, and if none exists, for such nominal rental fee as determined by the City Clerk, provided that all candidates for an office are invited to attend such meetings.

b) No Member of Council shall use the platform of a town hall, ward meeting, committee meeting or meeting of Council to make reference to their Election Campaign or for any election-related purpose.

c) In accordance with the Election Sign By-law, Campaign-related Signs or materials shall not be displayed or distributed at or in City or Local Board owned or leased facilities at any time. The exemption being the City’s long term care home (Dearness Home). Pursuant to section 28 of the Residential Tenancies Act a landlord cannot restrict reasonable access to a residential complex by candidates for election to any office at the federal, provincial or municipal level. 

4.2 Prohibition Against Use of City Resources for Election Purposes

a) City resources shall not be used by any Candidate, Third Party Advertiser, campaigns related to a question on a ballot or political party for Election Campaign related purposes. City resources include, but are not limited to:

(i) newsletters, communications and flyers;

(ii) City employees;

(iii) City funds;

(iv) print or electronic materials paid for with City funds promoting a Candidate;

(v) photos or videos produced by the City, including electronic images and videos;

(vi) City mail room supplies and services.

(vii) City print room supplies and services;

(viii) City technical services and equipment (e.g. computers, laptops, mobile devices and applications such as voice mail, e-mail, Internet and Intranet, City web pages and domains, etc.);

(ix) registered trademarks held by the City of London and the City of London Coat of Arms (e.g. City of London Logo.); and

(x) lists and files produced using City Resources, except for lists produced for election purposes and when used in accordance with the Municipal Elections Act, 1996 (e.g. Voters’ List).

4.3       Restricted Period 

a) During the Restricted Period, the following City resources, events or activities shall not be provided to, used by, or engaged in by Members of Council. City resources may also be restricted. The following is a list of restrictions that will apply during the Restricted Period:

(i) Member of Council’s communications including but not limited to flyers, householders, newsletters, advertisements, mail outs shall not be issued unless advising of a Ward meeting held more than sixty (60) days in advance of Voting Day;

(ii) ward meetings shall not be held within 60 days of Voting Day.

(iii) communications with constituents that are unrelated to current City business or communications that are not responsive to questions, concerns or matters raised by constituents relating to City business are prohibited when using City resources or while engaging in City business;

(iv) content related to Members of Council on london.ca shall become static, with no further updates, and biographies shall be removed;

(v) links on london.ca to a Member of Council’s website(s) and social media account(s) shall be removed;

(vi) any references made to the Member of Council in communication materials or at the event itself shall be to the “Ward Councillor for Ward ___” or “Chair of the ___ Committee,” rather than by name;

(vii) a Member of Council shall not use City resources, including their expense budget, to purchase a ticket to a community event. 

b) The following is permitted during the Restricted Period: 

(i) external organizations such as community groups and other levels of government may continue to invite Members of Council to attend and participate in events in their capacity as elected officials;

(ii) Members of Council may attend community events in their capacity as an elected official provided their participation an/or attendance is not advertised in any City or Member of Council issued communications materials (e.g. brochures, websites, pamphlets, signage, social media posts, newsletters, invitations, news releases, etc.);

4.4       Federal and Provincial Elections 

a) During an Election Period for the provincial or federal elections, MPPs and MPs, should not be invited to attend City events.

4.5       City Employees

a) City employees shall not engage in any Campaign-related Activities during business hours unless they are on paid or unpaid leave.

b) During an Election Period, information deemed valuable to all Candidates shall be posted on a public platform such as the City's website or other accessible channels by the applicable Service Area and staff, to guarantee transparency and equal access.

c) Any tours or meetings with members of Civic Administration must be offered to all candidates if a member of Civic Administration agrees to meet or arrange a tour with a Candidate.

4.6       Related Resources:

Last modified:Friday, June 06, 2025