My concern is that you've essentially set up a system in which somebody monitors and investigates and then reports to somebody else, either to the House, the Prime Minister, the public, or somebody, and also has an advisory role. That is essentially what I would call a specialty ombudsman kind of role. Ombudsmen typically investigate and then try to persuade whoever it is they're reporting about to make a change. They don't usually have order power. They don't have the power to levy fines and penalties. It's true that the Conflict of Interest Act has created a kind of hybrid, because in this you do have a commissioner who can levy some penalties for some circumstances.
But I think if you go the full route and if you say the commissioner can now levy significant penalties in relation to substantive breaches of the rules, you're going to need to set up a system that allows greater protection of the person's rights about whom the breach has been alleged and found to have occurred. You may see us go down the road that the American jurisdictions have gone down, which is to create essentially ethics commissions that are forms of administrative tribunals only they're more powerful than the average administrative tribunal. They can order fines and in some cases order people into jail.