Information & Ethics Committee on June 1st, 2026

[Linda Lapointe, Liberal, Rivière-des-Mille-Îles, QC]

Would you have anything to add, Mr. Shore?

[Jacques Shore]

It's almost the same on my end. However, I can add a comment about my experience over the past 30 or 35 years.

I have had a lot of experience in dealing with the legislation from way back. I was dealing with the lobbying registrar, as they were then called. I was advising the office of the lobbying commissioner here at the federal level. I was working at the provincial level too and assisting clients who have been penalized for the way in which they may not have addressed the detail of the legislation.

More so, because of the privilege of the practice of law that I have, which is an advisory component and a component in which I'm dealing with major issues when we deal with government, I also have to be very mindful for myself. I find myself having to ensure that I am, on those occasions when I am “lobbying”, an advocate. Whether I'm before a minister or whether I'm before a judge, to me it's the same, in a sense. It's my factum that I'm sharing in terms of educating the particular individual in government that I'm dealing with. I have to make sure of the letter of the law. As a result, I've been called upon for my advice in making sure that clients respect the letter of the law as well.

[Linda Lapointe, Liberal, Rivière-des-Mille-Îles, QC]

Thank you very much.

In the brief you submitted to the committee, you mentioned the importance of avoiding a regime where the compliance burden ultimately discourages legitimate engagement.

Do you believe that lobbying is a necessary element of democracy? If yes, why is that?

What are the consequences if we end up with a lobbying regime that is too burdensome?

[Suzanne Sabourin]

To answer your first question, I would say that yes, lobbying is an important activity.

Like my colleague Mr. Shore, I consider myself more of a representative or spokesperson than a lobbyist, because my goal is to represent my clients as best as I can. In a democratic society, this leads to political engagement or informed engagement within which viewpoints can be exchanged in the hope of arriving at the best possible solution that is in the public interest. That's fundamental for me.

[Linda Lapointe, Liberal, Rivière-des-Mille-Îles, QC]

Thank you.

Mr. Shore, can you also answer the question?

[Jacques Shore]

In my opinion, it's essential that there be genuine debates and discussions between government people and the public.

[Linda Lapointe, Liberal, Rivière-des-Mille-Îles, QC]

I agree with you. No one has the real solution. It's by discussing different points of view that we can probably arrive at the best law or the best consensus. What I mean is that members of all parties in Parliament have different viewpoints, but maybe by talking together, we'll find a better solution.

[Jacques Shore]

I think we have a good, delicate balance. Respectfully, in my view, what is being proposed is that we go overboard. We will do more than is necessary. We want to make sure that the public understands that transparency is important, but we also want it to be understood that there's integrity when we deal with public office holders.

This applies to the other side as well. I think there's a suspicion that when lobbyists are speaking to government, it's something sinister, but it's not. It's about the exercise that's necessary for government to better appreciate all sides and all issues.

[The Chair, Conservative, John Brassard]

Thank you, Mr. Shore.

Thank you, Ms. Lapointe.

Mr. Fortin, you have the floor for six minutes.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Thank you, Mr. Chair.

Ms. Sabourin, Mr. Shore and Ms. Santini, thank you for being with us today.

Ms. Santini, I understand that your organization is against registration by default. Am I mistaken when I say that?

[Christina Santini]

No, you are not mistaken.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

I'd like to know why you are against that. I'm not a lobbying specialist and I may be mistaken, in which case you will correct me, but what I understand is that the issue of thresholds is problematic. It's a bit cumbersome to manage when there are thresholds of 32 hours, 8 hours and so on, so several countries have adopted the registration by default rule. It seemed appropriate to me. I'd like you to explain to me further why you are against this measure.

[Christina Santini]

Often, a small business owner who pays themselves a salary from their business will face a problem. It could be a case where one of his employees calls on him to intervene or a situation where the policies of the Temporary Foreign Worker Program change, or the notices….

Excuse me, I'm going to respond to you in English.

Oftentimes, they will have an issue, and they will raise it with their local MP. Sometimes they will also ask or state that this policy should change, and they put forward the recommendations they would make.

We would not want that discussion, through registration by default with no threshold, to suddenly mean that they have to register and put in that communication when right now that conversation would have taken 30 minutes. Right now, they don't have to set up a profile, and they don't have to report that exchange. They're venting their frustration, and they're putting in a recommendation as a citizen. They're a business owner trying to operate their business, and they're frustrated with a specific policy change that's been brought forward.

Registration by default would mean that, given that they're remunerated by their business, they have to declare it, that they are an in-house lobbyist. That is a concern. Even bringing it down to eight hours is a concern because we have some members who have faced serious issues. They are very concerned about the future of their business, and they've communicated with their MPs and tried to get meetings. They've also met with the minister. That becomes lobbying, especially as soon as they get to the eight-hour threshold. However, they're only looking at their specific case or at how policies apply to their specific case.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

I apologize for interrupting. As Mr. Chair was telling us earlier, we have limited speaking time. We're forced to be rude.

In a few words, what do you recommend?

[Christina Santini]

We're requesting that the threshold be regulated and that it be more than 8 hours, as this is too little. A threshold of 32 hours would be better. Furthermore, the notion that requesting grants or contributions, for example from Canada summer jobs, is considered lobbying should be removed. Filling out these forms takes time.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Thank you.

Ms. Sabourin and Mr. Shore, do you share the same opinion as Ms. Santini on this matter?

[Suzanne Sabourin]

I agree, in that the registration threshold should be regulated by Parliament. However, I'd like an in-depth consultation on the implications. We used to have a system where the threshold was set at 32 hours per month. Now, we operate under the eight-hour regime over a period of four consecutive weeks.

Is there a more reasonable middle ground? Are there any options for the non-profit sector? I won't go into too much detail, but I know that the special committee studying the British Columbia law made recommendations to lighten the burden for small and medium enterprises and the non-profit sector.

[Jacques Shore]

I'm going to add something. It's important that there be consultation. This needs to be addressed. I would like to know how members of Parliament feel about that. I'd like to know how they would feel about their constituents suddenly being put in this position. I think it requires a debate.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Thank you.

I'm changing the subject completely.

The commissioner also recommends that board members be considered employees. What do you think, Ms. Sabourin and Mr. Shore?

[Suzanne Sabourin]

Honestly, I was fortunate to read the testimony of the Honourable Joe Jordan, and I support his recommendation. I believe it's a practical and very reasonable approach.

[Jacques Shore]

I also agree with Joe Jordan. I would add something else, though.

It will certainly be important for all of those boards that are out there to ensure that their directors appreciate what that is. My concern is this: You have voluntary boards, and you have boards in which individuals are dealing with matters that are of importance to them. For them to feel that if they run into their member of Parliament or a minister and they have the opportunity to talk about something that is important, such as a cultural issue or a particular issue dealing with homelessness, but they now suddenly have to register....

I wonder what the value of that is. I certainly wouldn't call that person an employee. I would make sure that it would be understood as an exception to the rule. It's not an employee. It's a director. I think that's worthy of debate as well.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Thank you.

Ms. Santini, can you quickly answer the same question?

[Christina Santini]

That's exactly what we're talking about. When there's informal interaction, to what extent should this activity be considered lobbying and discussed? It should also be possible to have such a discussion as an individual.

Consultations would be welcome.

[Rhéal Fortin, Bloc, Rivière-du-Nord, QC]

Is my speaking time over?

[The Chair, Conservative, John Brassard]

You have 10 seconds left.