It’s not always what you say that is most interesting, sometime what you don’t say is far more telling. And in the case of Charlottetown accounting firm Arsenault Best Cameron Ellis what is of interest is whether the firm red flagged any issues surrounding the controversial Provincial Nominee Program.

Arsenault Best Cameron Ellis enjoyed a dual role in the provincial nominee story. On one level it acted as the auditor for Island Investment Development Inc., the provincial body that managed the PNP program. On the other hand it acted as one of seven provincially appointed intermediaries that matched potential immigrants to Island businesses, and in the process likely generated millions of dollars in revenue for the firm.

Valid questions are being raised about whether this dual relationship constitutes a conflict of interest. It certainly seems the case. The Rules of Professional Conduct for chartered accountants stipulate that “the member be, and be seen to be, free of influences which would impair the member’s objectivity.”

The test to determine conflict is what would an ‘ordinary observer’ believe. It’s hard to imagine any ‘ordinary observer’ not seeing this as a conflict.

Tangible insight may be found in the management letters Arsenault Best Cameron and Ellis wrote to IIDI as part of its annual auditing process. The Graphic obtained the letters under the Freedom of Information and Protection of Privacy Act.

In its role as auditor, the firm is required to red flag any issue it observes to senior management. This is done in the form of a letter. For instance, in 2007 the firm, ironically, raised potential conflict of interest as an issue involving IIDI staff and the handling of good faith refunds to immigrants.

In 2004 it raised concerns about a lack of oversight by the IIDI board of directors – an issue that the Auditor General raised four years later in his examination of the PNP program. Cameron Best never raised the board issue again even though the lack of active oversight continued.

Just to show how out of touch the board was, records indicate it did not even follow through on the most basic of decisions and pass a motion to formally appoint Arsenault Best as the auditor of record for 2008-2009.

The management letters are most interesting when compared to issues raised by the Auditor General in his review of the PNP program.

One example. Because of liability fear, intermediaries were required in 2006 to provide a security deposit of $300,000 with IIDI. The seven intermediaries met this new condition in different ways. However, in one case the letter of credit had expired and another was set to expire. In two cases the funds could only be accessed with a court order. The auditor general’s report found that IIDI did not do an adequate job ensuring the security deposits were properly maintained.

Arsenault Best Cameron Ellis did not raise this issue in any management letter released under the FOIPP request.

In fact the firm’s management letters are largely silent on issues pertaining to the Provincial Nominee Program, especially after the Ghiz government ramped up the application process. In a boilerplate cover letter the firm states: ‘The maintenance of an adequate system of internal control is the responsibility of management.’

That aside, the laissez faire attitude of Innovation Minister Allan Campbell toward the integrity of the auditing process is troubling. Questions should have been raised after the auditor’s general’s report was tabled. Realistically they should have been raised years ago.

That didn’t happen, and as recently as two weeks ago the minister claimed no conflict exists.

That only proves one thing.

Allan Campbell is not an ordinary observer.

The auditor general raised specific issues that Arsenault Best Cameron Ellis did not.  The question is why?   Ordinary observers already know the answer.