It's called the Lobbying Act; it's not called the democratic freedom act. I think that the lobbying code of conduct should be about what you are doing as you are communicating, as you are lobbying. The first version of the code of conduct had this: Please tell the truth, please don't share secret information and please ensure that you are communicating with your various different clients. Don't lobby for both apples and bananas. You can only lobby for one. You can't have interests that are different from one another, though I find both delicious.
The new approach to retroactively look at different activities, which then places limitations on what you can do as a lobbyist, I think is beyond the purview of the Lobbying Act. I think we should focus on the registration to ensure that it's transparent and focus on the activities on a going forward basis, not what I used to do a long time ago.