Yes. The conflict of interest commissioner has used a definition. She's defined a close personal friend, in relation to the difference between acquaintances and close personal friends. I find that to be a definition that does make it a little clearer to work with.
When I was doing the consultation I actually heard, from some lobbyists, some concerns like the ones you're raising, but also an appreciation that there were certain friends they were not lobbying because they didn't want to put that particular friend in a conflict of interest. Those are the friendships I'm trying to address in this code, because of the court case.