There is a consideration around whether the OPC issues those AMPs. That introduces a different set of considerations.
One is that you're converting an ombuds that was created as an agent of Parliament and has a very particular function. An ombuds is not a determinate body. It's an advice-giving body. That's why it was created as an ombuds. It's because of the nature of an agent of Parliament. You are entrusting an agent of Parliament and moving them from an ombuds function to an enforcement function. You are in effect grouping an investigatory function, a findings function and a penalties function. By all considerations of natural justice in administrative law, there should be appropriate mechanisms in place to segregate those functions. We do that in a number of particular types of instances. There are ways in which we can contemplate how to separate those functions.
Essentially, you have two considerations there. One is that you've grouped them all, which we have concerns about because that's not, to our mind, a consideration of how you actually achieve natural justice or administer it in due process. Two, you've given it to an agent of Parliament that is presiding over private sector actors. Most agents of Parliament preside over government functions.