I follow the wording of the act or the code when I determine what the bar is, and, as I indicated earlier, sometimes the bar in the letters and in the accountability guide is higher.
I frequently give what I call hard advice and soft advice to people. I'll say “Look, you're not contravening the act if you do whatever, but it may look like you're contravening the act, so consider whether you want to take the risk. You know, the Globe and Mail test.”
Basically, the conflict screens are meant to address these issues, and maybe I should explain a little about how the conflict of interest screens work.
We set up a mechanism whereby anything that looks like a matter that might be a conflict is received by an assistant or a deputy minister or somebody else it's going through, and it's stopped. If somehow something makes its way through, if something slips through by accident, there is the mechanism of recusal. That's not only within the department; it could be in any of their activities, because somebody's managing their work schedule. There are two levels of dealing with these kinds of issues.
However, just because somebody has an interest in something that may appear to be a conflict, if they have adequate screens to stop them from having that problem, that's what happens.