A lot of people misunderstand the act. They say, "Wait a second, they didn't do anything to help anybody." No, the act is there to prevent you from doing that. If you do something to help someone, then you're in breach of trust. If they gave you any favour or benefit in order for you to do something, then that's the anti-bribery provision in the Criminal Code.
The act is there as a civil, non-criminal means to prevent these things from happening. The Supreme Court of Canada has ruled that it's essential; if it's not strictly and strongly enforced, then we don't have a democracy. It ranks just below the Criminal Code in terms of importance of maintaining government integrity. I think the penalties should be, as a result, very high. I believe one year's salary for a violation of these key rules that are there in the act should be the minimum penalty that the commissioner is required to impose. You are all supposed to be upholding the public trust. When you violate this act, you violate the public trust. The penalty should be very severe.