Actually, in that area she's issued a guideline that's multiple pages, very detailed, and gives lots of examples. I think the area of gifts, actually, that guideline, is the most defined line in the act currently, because of this guideline that the commissioner issued several years ago.
The words “improper advantage” need to be defined. No one could be found guilty of violating that rule currently, because as a case involving former cabinet minister Sinclair Stevens proved, the Federal Court ended up ruling and saying that he was found guilty of being in conflict of interest, but the conflict of interest wasn't defined and therefore he wasn't guilty because he didn't know where the line was and how could he know whether he crossed it.
On general application, what is a matter of general application? That has not been defined. I think it means lots of things. Maybe in the commissioner's mind it doesn't mean as much. It's a very important rule in the act in both the MPs' and senators' codes, because it's a huge exemption where it says you can't ever be in a conflict of interest if you're dealing with the matter of general application.
Those would be the two, though.
She's defined what a significant official dealing is in terms of you can't take a job with someone after you leave if you've had significant official dealings with them. She's issued a guideline on that. She's issued a few interpretation bulletins, but the big one is improper advantage, and the other one is general application. Those two should be defined by her in an interpretation bulletin or within the act itself, specifically.