Mr. W. Scott Thurlow at the Access to Information, Privacy and Ethics Committee

I'm happy to do so. Thank you very much for the question.

Section 10.2(1) of the Lobbying Act specifically says, “The Commissioner shall develop a Lobbyists' Code of Conduct respecting the activities described in subsections 5(1) and 7(1).” Once you are receiving payment to try to influence public policy, that is what the code of conduct applies to. It does not apply to the things that happened before.

Now, neither subsection 5(1) nor subsection 7(1) refer to the political activities of lobbyists. The plain language of the statute limits the authority to act of registration and the communications that give rise to those registrations, not any activity that occurs before those communications are contemplated.