In looking at those particular events, you're correct in that I look at it from the lobbying perspective. Is lobbying occurring? Looking at it from the act, did lobbying occur? Is it properly reported? Then I look at the code of conduct for lobbyists to ensure they have abided by the code, or in other words that they have acted with the highest ethical standards. What I can say is that in the new code, which I think is a stronger code, it talks about some of the activities that could place public office holders in a real or an apparent conflict of interest. Those terms are specified in the code, namely preferential access, such as where there's a close bond of friendship with a family member, for example, or giving gifts, or political activities.
In the guidance that I have provided on political activities, I have said that some activities create a sense of obligation and some activities do not. For those activities that create a sense of obligation, they should not lobby that particular individual for a period of five years.
Some of the activities I've said do not create a sense of obligation. I appreciate we're in a democracy with other acts like the Canada Elections Act, which are fairly stringent, but you can donate as per the Canada Elections Act, and that would not be seen as creating a sense of obligation. At the other extreme, organizing a fundraising event is something that I have said creates a sense of obligation, but we have been seeing questions on this pay to access recently. Given that I've always said I take allegations of breaching the code or the act seriously, then placing a public office holder in a conflict of interest is something that would be a potential breach of the act.
What I'll say is that I'm currently looking into that matter at this point. I don't have a further comment, but I am looking into it.